Forest Service Planning: Accommodating

Uses, Producing Outputs, and Sustaining

Ecosystems

February 1992

OTA-F-505

NTIS order #PB92-152560
Recommended Citation:

U.S. Congress, Office of Technology Assessment, Forest Service Planning: Accommodating

Uses, Producing Outputs, and Sustaining Ecosystems, OTA-F-505 (Washington, DC: U.S.

Governrnent Printing Office, February 1992).
Foreword

America’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 of

those lands are owned by the Federal Government. Forests and rangelands generate clean

water, 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 and

services rises as the country’s population grows and leisure time increases. Thus, we are faced

with 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 natural

resources and to increase public involvement in associated policy and budget debates. In 1976,

Congress amended RPA in the National Forest Management Act (NFMA) to guarantee

sustainable management for the national forests managed by the USDA Forest Service and to

assure active public involvement in the forest planning process.

Congress questioned the effectiveness of planning at the forest level under NFMA and

expressed concern over the direction the process is headed. Most local forest plans have taken

much longer to complete than anticipated, and frequently Congress has been asked to address

controversial issues that it expected to be resolved in the planning process. Numerous

administrative 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 and

Insular Affairs Subcommittee on National Parks and Public Lands and the Senate Committee

on Agriculture, Nutrition, and Forestry, requested that the Office of Technology Assessment

examine the Forest Service’s use of resource planning technologies. In Forest Service

Planning: Setting Strategic Direction Under RPA, released in July of 1990, OTA evaluated

past RPA efforts and identified options for improving RPA’s contribution to long-range

planning and to policy and budget deliberations. This second OTA report on forest planning

evaluates technological, biological, social, economic, and organizational dimensions of

national forest planning. It discusses the agency’s planning technologies, the appeals and

litigation processes, and the relationship between national planning under RPA and

forest-level planning under NFMA. The assessment presents options for Congress that could

improve forest planning under NFMA.

u JOHN H. GIBBONS

Director

.,!

M
Forest Service Planning: Advisory Panel

Hanna J. Cortner, Chair

Professor, Water Resources Research Center

Clark L. Collins

Executive Director

Blue Ribbon Coalition

Pocatello, ID

Richard C. Collins

Professor/Director of the Institute

of Environmental Negotiations

School of Architecture

University of Virginia

Charlottesville, VA

Dennis P. Dykstra

Professor of Forestry

School of Forestry

Northern Arizona University

Flagstaff, AZ

Paul V. Ellefson

Professor, Department of Forest

Resources

University of Minnesota

St. Paul, MN

Jerry Franklin

Bloedel Professor of Ecosystem

Analysis

College of Forestry

University of Washington

Seattle, WA

George T. Hamilton

Consultant

Recreation Resources

Management Co.

Bow, NH

University of Arizona, Tucson, AZ

Willard I. Hamiltonl

Coordinator, Timber Resource

Policy

Potlatch Corp.

Lewiston, ID

Betty Huskins

Vice President

Ridgetop Association

Linville Falls, NC

Andy Kerr

Director of Conservation and

Education

Oregon Natural Resource Council

Portland, OR

Dennis C. LeMaster

Professor and Head

Department of Forestry

Natural Resources

Purdue University

West Lafayette, IN

William S. Platts

Fisheries Consultant

and

Don Chapman Consultants, Inc.

Boise, ID

Robert Ragon

Executive Vice President

Sun Studs, Inc..

Roseburg, OR

Gerald A. Rose

Director/State Forester

Division of Forestry

Minnesota Department of Natural

Resources

St. Paul, MN

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

R. Neil Sampson

Executive Vice President

American Forestry Association

Washington, DC

Maitland S. Sharpe

Conservation Director

Izaak Walton League of America

Arlington, VA

E. Maynard Smith

Rancher

Smith 6-S Livestock

Glen, MT

Gaylord L. Staveley

President

National Forest Recreation

Association

Flagstaff, AZ

A. Milton Whiting

Chairman and Chief Executive

Officer

Kaibab Industries, Inc.

Phoenix, AZ

Louisa L. Willcox

Policy Director

Greater Yellowstone Coalition

Bozeman, MT

NOTE: OTA appreciates and is grateful for the valuable assistance and thoughtful critiques provided by the advisory panel members. The panel does

nofi however, necessarily approve, disapprove, or endorse this report. OTA assumes full responsibility for the report and the accuracy of its

contents.

iv
OTA Project Staff-Forest Service Planning

Roger C. Herdman, Assistant Director, OTA

Health and Life Sciences Division

Walter E. Parham Program Manager

Food 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 assistance

provided in this report. CRS graciously granted Ross Gorte a 14-month detail to direct this

study, 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 this

study 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

Contents

Page

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 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

3

17

33

59

77

109

127

143

163

179

187

203

vi
Chapter 1

Summary
Contents

Page

Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . ● *................**””*”””” . *.”””””””””””””””””” 3

Forest Planning as Strategic Planning . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 4

Multiple Use and Sustained Yield . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4

Public Involvement in Forest Planning . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4

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

Forest Planning Technologies. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6

Economics in National Forest Planning . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .... 7

The Budgeting Process . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .... 8

Organizational Factors in Forest Planning . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8

NFMA Forest Planning in Relation to National RPA Planning . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9

Role of Congress . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ....”.......””.” 10

Boxes

Box Page

l-A. NFMA Planning . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 3

l-B. Trust Fund . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5

Table

Table Page

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

Summary

INTRODUCTIO N

The Forest Service is one of the major Federal

land managing agencies. It has been part of the

Department of Agriculture since 1905, and now

manages some 191 million acres of land in 43 States.

The Forest Service Organic Act of 1897 and the

Multiple-Use Sustained-Yield Act of 1960 (MUSYA)

guide the management of these lands, providing for

a variety of uses and outputs---commodities (e.g.,

timber, livestock forage, and fuels and minerals) and

unmarketed values (e.g., recreation, wildlife habitat,

and water flows)--and requiring management for

sustained productivity.

The laws provide little guidance on how to

balance the various resource values and assure

sustainability. Initially, conflicts were managed by

separating uses over space or time. However,

demands on the resources have continued to climb,

and unmarketed resources are now more widely

valued by our society. Congress enacted the legal

requirement for national forest planning in the

Forest and Rangeland Renewable Resources Planning Act of 1974 (RPA). The principal purpose of

RPA was to establish a national strategic planning

process for meeting these conflicting demands while

assuring the sustainability of America’s renewable

resources. RPA also directed the Forest Service to

prepare integrated land and resource management

plans for units of the National Forest System. As part

of the RPA Program, the Forest Service was to

develop the plans in accordance with MUSYA and

the National Environmental Policy Act of 1969

(NEPA).

Congress amended RPA with the National Forest

Management Act of 1976 (NFMA). (See box l-A,)

NFMA was largely a response to lawsuits that would

have substantially reduced Forest Service timber

sales. The new law provided guidance for forest

planning by further emphasizing environmental

considerations and quality standards. Congress also

intended NFMA to aid in implementing MUSYA.

Under NFMA the Forest Service retained much of its

discretion in managing the national forests, but was

required to involve the public in the planning

process.

Significant administrative and legal challenges

have plagued national forest management and forest

plans over the past 10 years. Congress has expressed

concern about potential impacts of appeals and

litigation on timber sales, employment, and budgets.

Some of these challenges call for improving Forest

Service compliance with environmental requirements. Others call for improving public involvement

in 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 Forest

and Rangeland Renewable Resources Planning Act

of 1974 (RPA). RPA, as enacted, required the

Forest Service to prepare land and resource management plans for units of the National Forest

System. The agency was to use an interdisciplinary

approach to integrate physical, biological, economic, and other sciences. NFMA added guidance

for public participation and for Forest Service

considerations and standards in the planning process. These land and resource management plans are

often called forest plans, and the process is typically

called forest or NFMA planning.

chosen as its analytical tool—for a planning process

that is complex and insensitive to nonuse values,

such as preserving endangered species.

This OTA report presents a comprehensive assessment of national forest planning by the Forest

Service. It evaluates technological, biological, social, economic, and institutional dimensions of

forest planning. The report discusses the appeals

process and the merits and weaknesses of the

agency’s planning technologies. It then presents

options for Congress that could improve forest

planning under NFMA.

- 3 -
4 ● Forest Service Planning: Accommodating Uses, Producing Outputs, and Sustaining Ecosystems

FOREST PLANNING AS

STRATEGIC PLANNING

Strategic planning is a process for establishing

management direction. The 1897 Organic Act,

MUSYA, NEPA, RPA, and NFMA implicitly require a strategic planning process for the national

forests. The Organic Act and MUSYA establish the

basis for the Forest Service to accommodate uses

and provide outputs while sustaining forest ecosystems. MUSYA acknowledges that people’s needs

determine the proper mix of uses and outputs, and

that the mix can change over time. NEPA provides

a framework for reporting intended actions and

possible results of those actions to the public. RPA

requires the Secretary of Agriculture to evaluate the

Nation’s renewable resources and to consider their

future use and sustainability. NFMA establishes

management considerations and environmental standards and guidelines, and requires public involvement

in developing and revising management plans.

Strategic planning goals must be specific enough

to provide clear direction for management activities

and concrete enough to measure success. A forest

plan should identify what kind of uses, outputs, and

conditions are feasible and desirable. It should focus

on issues of public concern, explaining how management will affect key sites, produce important

outputs, and protect vital resources and ecosystems.

By focusing on issues and explaining management

changes, a strategic forest plan can guide the agency

and inform the public.

MULTIPLE USE AN D

SUSTAINED YIEL D

Multiple use, according to MUSYA, is the management of renewable resources on the national

forests to best meet the needs of the American people

without impairing the productivity of the land. The

Act calls for forest management based on relative

resource values, not just on maximizing returns or

outputs.

Multiple-use management has come to mean

either joint production (using the same land for

several uses simultaneously) or dominant use (using

different parts of the land for different uses).

Management based on joint production is difficult

because of the lack of biological and social information on ecological interactions. Dominant-use management is complicated by the difficulty of determining which lands to manage for which uses.

Multiple use, to some, implies use of commodity

resources (e.g., timber, livestock forage, and minerals). Areas where laws restrict commodity uses,

however, such as recreation sites and wilderness

areas, can still produce multiple values (e.g., recreation, wildlife habitat, and water flows). As a concept,

multiple use assures consideration of varied resource

uses and outputs, and seeks an appropriate balance

among these. However, the concept provides little

guidance for managers on how to balance conflicting

uses and outputs.

MUSYA represents the frost attempt by Congress

to apply the goal of sustained yield broadly, to all

renewable resources. Sustained-yield management

requires maintaining the productivity of the land

while producing high levels of annual outputs.

Sustained-yield management of the national forests

has been compromised by a lack of knowledge about

ecological and social relationships and by a technical bias favoring production of individual resources

over ecosystem management and protection. (See

box l-B.)

PUBLIC INVOLVEMENT IN

FOREST PLANNING

The Forest Service has a long history of soliciting

public input in its decisionmaking processes. Before

NFMA, this was generally informal and sporadic.

With the enactment of NFMA, Congress reinforced

the public’s right to participate in agency planning

and decisionmaking. NFMA embraces the notion

that conflicts can be addressed best by integrating

the public into the decisionmaking process early and

often.

Consensus today is that the Forest Service has not

used public input efficiently or effectively in its

planning process. Much current criticism is similar

to that heard at least 20 years ago: the agency asks

for public input, but the input does not affect final

decisions. Despite numerous opportunities for individuals and interest groups to participate throughout

the planning process, many final forest plans appear

not to accommodate public concerns.

The ineffective involvement of the public in the

planning process may result from several factors:

use of incorrect models of public involvement, lack

of 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 provide

continuous and permanent natural resource benefits. The 1897 Forest Service Organic Act established forest protection, stable water flows, and

continuous timber supplies as the purposes for

forest reserves. The Multiple-Use Sustained-Yield

Act of 1960 requires the Forest Service to maintain

the productivity of the land. Such direction shows

Congress’ desire to maintain the resources of the

national forests, much as the assets of a trust fund

are conserved. In the forests and the trust fund,

managers are responsible for protecting the assets.

Annual benefits are important, but preserving the

productive assets is paramount.

Two aspects of the National Forest System

complicate the trust fund analogy. First, the annuities of the National Forest System include not only

uses and outputs, but also nonuse values (e.g.,

various aspects of relatively undisturbed ecosystems). Second, the Forest Service, as required by

law, provides the public with opportunities to

participate in the national forest planning process.

Thus, the public both benefits from and influences

the management of the National Forest System.

This contrasts with traditional trust funds, where the

beneficiaries are relatively isolated from trust

management.

professional resistance to the public’s ideas, and

inflexible conditions for managers. Most national

forest managers still fail to recognize the purpose of

public involvement, believing public participation is

primarily an exercise in gathering information.

In fact, there are several reasons to involve the

public in the planning process. First, the public must

agree to, or at least accept, the management activities for the national forests and the overall direction

management takes. The public is more likely to

accept decisions if it has been involved in the

process, understands the limits of the resources, and

sees that consensus sometimes cannot be reached.

Public participation also can serve as an early

warning system. Public comments can alert agency

planners to issues and concerns that are likely to

cause significant controversy in the future. By

working with the public, agency planners can

develop plans that address current and emerging

concerns and, thereby, avoid making decisions that

prompt appeals and delay implementation.

No one best way exists to facilitate public

participation in forest planning. The most effective

means vary with decisions to be made, geographical

setting, and preferences of the local publics. For

example, a town meeting might work well in New

England where town meetings have a rich history,

but might fail in other parts of the country. Furthermore, some people like public hearings while others

prefer personal interaction. Whatever procedures are

chosen should encourage and stimulate debate, and

managers should clearly respond to public desires

and concerns. Otherwise, citizens and interest

groups will seek other forums, such as Congress or

the courts, to influence forest policy and decisionmaking +

The administrative appeals process offered by the

Forest Service is best characterized as an extension

of public participation provided for under NEPA and

NFMA. The process allows any individual to request

an agency review of forest plans or agency decisions. The administrative appeals process has helped

the Forest Service to: 1) clarify planning decisions;

2) set standards for environmental analyses required

by NEPA; and 3) resolve various issues, such as use

of management indicator species, protection of

biological diversity, and adequacy of resource monitoring plans. The appeals process has been costly

and time-consuming, because it has forced the

agency to resolve complex questions under NEPA

and NFMA. However, what has been learned from

the frost round of plan development may make later

revisions easier. The number of administrative

appeals is surprisingly small, given the level of

concern, but may be locally significant, and the

Forest Service has often not met the deadlines

specified in the regulations. Data on the number,

location, rationale, significance, and effects of

administrative appeals are not available, however,

so it is impossible to evaluate the effectiveness of the

current system.

Litigation is the final recourse for individuals or

groups dissatisfied with Forest Service decisions.

Judicial review assures that decisions are consistent

with legal direction. Despite the substantial controversy surrounding spotted owls and old-growth

forests in the Pacific Northwest, few Forest Service

plans or activities are litigated. Congressional efforts

to change the judicial review process seem to be

attempts to resolve substantive issues without appearing to take sides. However, such changes are

unlikely to improve forest planning or plan imple-
6 ● Forest Service Planning: Accommodating Uses, Producing Outputs, and Sustaining Ecosystems

mentation, or to reduce conflict over national forest

management.

BIOLOGICAL DIMENSIONS OF

FOREST PLANNING

Strategic planning depends on an analysis of

resource conditions and trends. Inventories provide

baseline data on forest resources. Monitoring then

permits an evaluation of trends in the quality and

quantity of these resources. Forest inventory and

monitoring activities have long been criticized for

failing to support integrated, multiresource programs. This failure is due largely to a historical

emphasis on timber resource inventories, inattention

to ecosystem processes, and insensitivity to the need

for statistically valid data analysis. These problems

are exacerbated by inadequate funding for these

expensive but necessary activities.

The Forest Service is specifically criticized for

not following NFMA inventory and monitoring

requirements and for generating sparse, poor quality,

and out-of-date information. It is also criticized for

failing to follow through with monitoring activities

described in the forest plans. Newly proposed 1991

regulations may strengthen the role of monitoring

and provide renewed emphasis on integrated, multiresource programs. Lack of money for detailed

monitoring, however, will require the Forest Service

to revise its monitoring plans to reflect more

accurately what is possible and what is most

important to accomplish under staff and budget

constraints and according to public interest.

Inadequate inventory data has made it particularly

difficult to address biological diversity comprehensively. Forest planning regulations require the Forest

Service to maintain diversity of plant and animal

communities and to select and monitor a set of

management indicator species. These species are to

serve as surrogate measures of the health of biotic

communities in relation to management activities.

However, the Forest Service lacks guidelines, training, and expertise to select and monitor indicator

species and some of the selected species have not

been monitored. Use of indicators should focus on

an improved selection process, and should provide

information on the consequences of management

activities as well as on current habitat conditions and

ecological processes.

FOREST PLANNING

TECHNOLOGIES

Technologies useful to forest management clarify

resource location, analyze resource availability over

time, and assess effects of decisions on ecosystems

and on human values. Computer models, as one

technology to help with these evaluations, provide

estimates of what might happen under various

management options.

The most useful technologies for examining

spatial resource interactions are geographic information systems (GIS). These systems can superimpose

locational data for two or more resources or activities (e.g., timber stands over soil types). In so doing,

GIS can contribute to resource management decisions and to public understanding of resource

interactions. These systems, however, are very

expensive to acquire and develop, and must be based

on reliable data. To date, the Forest Service has not

used GIS extensively in forest planning, largely

because of program and funding restrictions imposed by Congress.

Linear programming is also a useful technology

for analyzing resource use. Linear programming

models for land management try to maximize

resource uses and outputs over time within ecological limits. The models can provide the Forest Service

with information on how to meet the requirements of

sustainable timber production and coordination of

timber harvesting with other uses. Linear programming, however, requires massive amounts of data to

define interrelationships among resources; excludes

analysis of risk and uncertainty; and necessarily

assumes direct, continuous, and reversible relationships among resources.

Resource simulation models are the principal

technologies used by the Forest Service for estimating ecological and environmental responses to

activities. These models try to quantify relationships

among resources and results of management actions.

Simulations such as timber growth-and-yield models and sediment yield models often examine consequences of management activities for a single

resource. The regional diversity of forest resources

has led to many unique, local models rather than

universal models. Simulation models commonly are

used as input to other models, such as linear

programming models.
Chapter 1--Summary ● 7

Economic and financial consequences of management must also be considered in planning. This can

be done, in part, by ex amining the benefits and costs

of the proposed activities, the approach taken in

FORPLAN. In addition, models are used to estimate

the local economic effects of management decisions.

Input- output analysis is the traditional model used,

and the Forest Service has developed variations of

such a model--IMPLAN--for forest planning.

The Forest Service designated FORPLAN as

the principal analytical tool for forest planning.

FORPLAN is a linear programming model that

maximizes the present net value of resource uses and

outputs (i.e., maximizes management efficiency)

within specified constraints. The Forest Service uses

FORPLAN because it performs certain tasks well

and because it helps organize planning around

selected issues. The strengths of FORPLAN include

its enormous analytical capacity; its focus on

important issues (i.e., how much timber can be cut

and from which areas); and its common language for

analysts.

FORPLAN is limited by its requirements for

massive amounts of data on ecological interactions

and for market prices for all resource uses and

outputs. FORPLAN includes nonuse values-such

as protecting watersheds, preserving endangered

species, and improving aesthetics-only as constraints rather than as goals. This implies that

sustaining ecosystems is a constraint on production,

and not a goal for managing the national forests.

Further, FORPLAN, and linear programming g generally, has little capability to analyze spatial concerns.

Some resource managers and public interests

mistrust FORPLAN because of its large size and

complexity, problems with documentation and verification, and poor understanding of how to use the

results in decisionmaking. Nonetheless, FORPLAN

can be a useful analytical tool if the Forest Service

uses it with other technologies and to support public

understanding.

ECONOMICS IN NATIONA L

FOREST PLANNIN G

Economic considerations in strategic planning for

national forest management involve determining the

balance among resource values and identifying

impacts of national forest management on communities. MUSYA calls for consideration of the relative

values of resources, while RPA and NFMA set up

requirements for economic analyses. Through these

requirements, Congress intended the Forest Service

to determine the proper balance among resource

uses, outputs, and protection through interaction

with the public. Although Congress rejected economic efficiency as the principal consideration for

managing the national forests, it has been emphasized in national forest planning.

The Forest Service uses FORPLAN as an economic efficiency model in national forest planning.

In terms of achieving economic efficiency,

FORPLAN is limited by uncertainties over the

comparability of market prices and other values,

difficulty in balancing uses and outputs with nonuse

values, and inaccurate cost and value data.

FORPLAN’s capability to assess efficiency of forest

management alternatives also is limited by the lack

of knowledge of quantity and quality changes in all

resource values that might result from the management activities.

Community stability is a common local concern

in forest planning. The Forest Service is limited in its

ability to assess and achieve community stability

because of imprecise definitions, the lack of measures of stability, the difficulty in measuring the

acceptable pace and amount of change, and the

agency’s inability to influence resource or product

demand.

The Forest Service uses IMPLAN, an inputoutput model adapted to each national forest, to

assess employment and related impacts on communities. However, the county-level data used can

mask differences among communities within a

county. Furthermore, input-output models only provide comparable analysis for certain resource-based

sectors. For example, the models define lumber and

wood products as a single manufacturing industry,

whereas recreation is scattered among several industries in the retail trade and service sectors.

Restructuring payments to counties based on

timber sales may provide one way for the Forest

Service to avoid causing community instability. At

present, the Forest Service returns 25 percent of its

gross receipts to the States for use on roads and

schools in counties that contain national forests.

Forest Service payments account for a large portion,

up to 80 percent, of operating budgets in some

Pacific Northwest counties. Timber typically accounts for most of the payments, usually 95 percent
8 ● Forest Service Planning: Accommodating Uses, Producing Outputs, and Sustaining Ecosystems

of the total nationally, but the payments vary widely

from forest to forest and from year to year. Thus, the

counties have little certainty about annual payments,

but are more likely to support Forest Service timber

sales than other activities in the planning process.

Fair and consistent compensation for the tax exempt

status of national forest lands and activities could

stabilize county payments, regardless of how the

lands are managed,

THE BUDGETING PROCES S

The annual Forest Service budget is the direct link

between Congress and national forest management.

Budgets in some forest plans have been constrained,

providing a picture of financially feasible opportunities; in other forest plans, budgets have been

unconstrained, providing an examination of a wide

array of alternatives. Unconstrained budgets probably will not mesh with spending realities, and do not

provide information on priorities, but constrained

budgets exclude possible opportunities. Because of

the different budget assumptions, the forest plan

budgets cannot be aggregated to a simple National

Forest System budget proposal.

The national Forest Service budget and appropriations are broken down by resource, in line item

appropriations. These appropriations must be translated into integrated resource projects by resource

managers. The imprecision of this translation and

the difficulty of setting priorities among the line

items has led to accounting data that may not reflect

actual expenditures for managing the resources.

Accountability is further complicated because target

accomplishments for commodity resources, especially timber, are readily measurable whereas target

accomplishments for noncommodity resources are

not.

End-results budgeting, as proposed by the Forest

Service, would collapse line items for national forest

management into one operation and maintenance

account. The agency would record separate line

items for investments, such as roads, trails, and

reforestation. The effectiveness of this budgeting

system depends on accurate measures for changes in

conditions of all resources in response to management activities. Although the General Accounting

Office (GAO) reacted favorably to a test of endresults budgeting, the necessary measures of condition to demonstrate the end results of management

are not sufficient at this time. Congress also may

perceive a loss in control over the budget for each

resource program. An alternative approach might be

congressional appropriations by activity+. g., planning, operations, maintenance and protection, investments, and monitoring.

Fourteen permanently appropriated special accounts or trust funds account for nearly a third of the

Forest Service budget. Six of the largest are principally related to the timber program. The Forest

Service has substantial discretion to determine the

amount of money deposited in four of these funds

—the Knutson-Vandenberg (K-V) Fund, the Salvage Fund, brush disposal, and other cooperative

deposits—which are to be used on the national forest

where the money was collected. Despite the substantial discretion to determine local budgets through

timber management activities, Congress has exercised little oversight or control over the special

accounts and trust funds.

ORGANIZATIONAL FACTORS

IN FOREST PLANNING

For at least half a century, the Forest Service was

viewed as a premier Federal agency. It was seen as

a strong and independent manager of public resources for the public good. Professionalism within

the Forest Service provided the basis for its long

history of success; however, as it is dominated by

professionals and technicians trained in forestry, the

agency has given emphasis to the management and

use of trees. Although this emphasis has had merit in

past national forest planning, public perceptions of

the relative values of forest resources have been

changing. Social values today are less utilitarian and

less accepting of traditional forestry practices that

may harm nonuse values of the forests. The profession and the agency have been changing, but many

believe the change is too little too late.

The Forest Service, in accordance with NFMA

and NEPA, has developed an interdisciplinary

approach to forest planning. The agency uses teams

of specialists in wildlife, forestry, recreation, engineering, hydrology, soils, economics, range, and

many other fields. A diverse workforce brings a

broader array of ideas, leading to increased creativity and flexibility for the organization. Efforts to

diversify have been overshadowed, however, by the

agency’s traditional organizational structure by resource function, especially at regional and national

offices. The emphasis on individual resources makes
.

Chapter 1--Summary ● 9

integrated project planning and implementation

difficult.

Most Forest Service employees believe that

timber production is rewarded by the agency above

other resource uses and values. More generally,

agency employees believe that productivity (meeting targets, working hard, and being competent) and

team spirit (loyalty, teamwork, promoting the Forest

Service image, and getting along with peers) are the

most rewarded organizational values. These organizational values differ from personal values held by

many Forest Service employees, who, regardless of

their professional training or level in the agency,

tend to value recreation over other uses, followed by

wildlife and water. Many employees also believe

that concern for healthy ecosystems should be

rewarded to the same degree as professional competence, hard work, and teamwork.

The mismatch between apparent agency and

employee values may reflect several difficulties.

These include changing established modes of operation, external pressures, and a reward system that

typically measures the tangible outputs of commodity resources and ignores the intangible unmarketed

and nonuse values.

To be implemented, the forest plans must be

technically and politically feasible, i.e., consistent

with scientific information, with public goals, and

with national decisions. Technical feasibility can be

assessed annually by comparing outputs, changes in

conditions, and unit costs with those in the forest

plan. Political feasibility can be measured, in part, by

the number of administrative appeals and lawsuits

filed against a plan. However, additional measures

of the effectiveness of public involvement and

manager responsiveness need to be developed to

assure that managers are properly rewarded.

NFMA FOREST PLANNIN G

IN RELATION TO NATIONA L

RPA PLANNIN G

RPA establishes a strategic planning process at

the national level structured around four documents:

the RPA Assessment, the RPA Program, the Presidential Statement of Policy, and the Annual Report.

NFMA establishes a strategic planning process at

the local level, using an interdisciplinary approach

and public involvement. The Forest Service regulations describe RPA-NFMA planning as iterative, in

that information from the forest level flows up to the

national level and information in the RPA Program

flows back to the forests. The Forest Service

historically approached planning as a hierarchical

process, allocating resource targets from the RPA

Program to the regions, and from the regions to the

forests. The 1990 process, however, was influenced

by a more integrated approach using information

from the plans in the RPA Assessment and in the

Program strategies.

The national forest plans provide information on

resource conditions and predicted results of proposed management actions. The RPA Assessment

provides information on resource outputs, conditions, and trends on national forests, private, and

other public lands. The RPA Assessment can serve

as a source book for forest-level planners. Forest

planners can design inventory and monitoring activities so data will be compatible with previous

inventories and studies in progress. Data can then be

more easily aggregated and used in a comprehensive

analysis in the RPA Assessment.

The forest plans also contribute to the RPA

Program, by identifying the public’s preferred management alternatives. Issues and concerns that are

widespread at the local level should receive special

attention in the Program. As a strategic plan, the

Program needs to set direction for national forest

planning as well as for Research and for State and

Private Forestry. The program, however, should not

override local decisionmaking. Instead, it can augment local planning by addressing regional, national, and global issues not identified locally and

provide direction for forest plan revisions.

The forest plans can provide information to the

Annual Report on expenditures and results of

management on each national forest. This information can be used to assure spending is balanced and

efficient. Reporting on expenditures, outputs, and

conditions should be consistent among forests and

with the RPA Assessment so data can be aggregated

and compared and trends assessed.

Target allocations from annual appropriations and

the RPA program are difficult to mesh with local

planning, primarily because targets are set only for

certain outputs. Forest managers lack measures for

annual nontimber outputs and nonuse values and,

thus, are generally ill-equipped to demonstrate

balance in achieving stated goals. Strategic planning

does not require eliminating national targets. In fact,
10 ● Forest Service Planning: Accommodating Uses, Producing Outputs, and Sustaining Ecosystems

targets are critical for reaching stated goals for

various resources at different times. Hard targets for

selected outputs, however, do not encourage an

interactive flow of information from the local level

to the national level and, thus, run counter to

functional strategic planning and the iterative process.

Resource capability information developed at the

local level is a base for RPA planning, whereas

national objectives are essential to strategic planning

and the setting of long-term goals. The process must

be centralized to take a comprehensive look at

overall direction and to integrate budgeting and

performance appraisal. However, the process also

must be decentralized to treat individual forests

appropriately and to assure that local plans are

technically and politically feasible.

ROLE OF CONGRES S

OTA has identified four major findings on forest

planning:

1. Plan development emphasizes timber and other

physical outputs.

2. Monitoring of forest management activities is

inadequate.

3. Budget decisions overwhelm planning decisions.

4. National targets can nullify local decisions.

In view of these findings, OTA has identified 14

options available to Congress to improve forest

planning under NFMA. These options are discussed

below under the corresponding finding. (See table

l-l.)

Finding 1: Plan development emphasizes timber

and other physical outputs.

The Forest Service emphasizes allocating lands

and producing physical outputs, especially timber,

in forest planning and gives little attention to

sust aining ecosystems. MUSYA, NFMA, and the

planning technology FORPLAN encourage the emphasis on timber and other physical outputs. Forest

plan implementation, budgeting, and national direction also emphasize land allocation and the quantitative, physical outputs of the national forests.

Option 1: Clarify legislative direction.

Congress could amend the laws guiding national forest planning and management to recogTable l-l—Major Findings on NFMA Forest Planning

and Possible Options for Congress

Findings Options

Plan development emphasizes

timber and other physical

outputs

Monitoring of forest

management activities

is inadequate

Budget decisions overwhelm

planning decisions

National targets can nullify local

decisions

Clarify legislative direction

Broaden the information base

Establish targets for all

resources

Improve public involvement

Expand use of information

technologies

Separate the monitoring

function

Require linkage between

actions and results

Require public involvement in

monitoring

Eliminate appropriations by

resource

Require realistic budgets in

forest plans

Control special accounts and

trust funds

Compensate counties fairly and

consistently

Specify forest plans as the

baseline for RPA planning

Require RPA direction for all

resources and all branches

SOURCE: Office of Technology Assessment, 1991,

nize the nonuse values of the national forests and

to assure the protection of the ecosystems that

generate the use and nonuse values.

MUSYA could be amended to expand the

purpose of the National Forest System. The expanded purpose could include providing for all the

use and nonuse values of forests and rangelands.

Multiple-use management could be expanded to

include multiple values of the lands, and focus on

sustaining national forest ecosystems. Amendments

to NFMA could require a determination of land

suitability for all management activities and could

require forest plans that aim to sustain all values,

including nonuse values.

Option 2: Broaden the information base.

Congress could require the Forest Service to

expand its forest planning inventory and analytical base to include necessary information and

models on all resources, on ecological interactions, and on social and economic impacts.
. .— —

Chapter l--Summary ● II

NFMA planning has initiated few resource inventories beyond those already used in forest planning

and management before NFMA. Inventory data and

models for the timber resource are more extensive

than those for other resources or for ecosystem

conditions. Data and models for examining economic results of management activities are more

complete for timber outputs than for other outputs

and conditions. Congress could direct the Forest

Service to balance its forest planning information

base and increase inventory funding, to assure that

analysis responds to public concerns over national

forest goals and management practices.

Option 3: Establish targets for all resources.

Congress could require forest plans to specify

targets for all resource uses and outputs, for

nonuse values, and for ecosystem conditions

identified as important by the public in its

participation in the planning process.

Congress intended forest plans to set the direction

for managing national forests. Current Forest Service databases and analytical tools, however, primarily measure physical outputs. Congress could require the Forest Service to develop measures that

more fully describe management direction for the

national forests. The Forest Service could then

identify targets for all uses and outputs, for nonuse

values, and for ecosystem conditions in the forest

plans and in RPA planning.

Option 4: Improve public involvement.

Congress could clarify the purposes for involving the public in forest planning, and could direct

the Forest Service to improve its public participation processes.

Vague guidance in the forest planning laws has

led the Forest Service and the public to conflicting

expectations about how public comments are to be

used in determining the future direction of national

forest management. The Forest Service model of

public participation impedes effective participation

because the public is viewed as an information

source for identifying output goals, rather than as

individuals and groups interested in all aspects of

management. Congress could amend NFMA to

direct the Forest Service to use public involvement

to build plans and decisions that are more acceptable

to society. The Forest Service also could improve its

public participation process by emphasizing the

importance of building

tions or compromises.

Option 5: Expand use

gies.

trust and acceptable soluof information technoloCongress could direct the Forest Service to

broaden the variety of technologies used for

information collection, analysis, coordination,

and presentation to assure that spatial and

temporal aspects of forest management are adequately addressed.

Current Forest Service planning technologies are

impeded by lack of information on resource interactions, have limited capacity for analyzing spatial

concerns, are difficult to understand, and emphasize

impacts on the timber industry over other industries.

Congress could direct the Forest Service to improve

its use of planning technologies by integrating their

principal tool for forest planning--FORPLAN—

with a GIS. The Forest Service also could be directed

to emphasize research on more complete models of

economic impacts. Finally, the agency could improve the coordination of data collection and storage, build a historical record for forest planning, and

contribute to an integrated RPA Assessment.

Finding 2: Monitoring of forest management

activities is inadequate.

An enormous amount of Forest Service and public

time and effort has gone into developing national

forest plans. Monitoring, however, has been inadequate to determine whether the plans are being

implemented. The inadequate monitoring results

from an inadequate database, insufficient funding,

and lack of incentives to monitor. It is difficult to

monitor changes in ecosystem conditions without

baseline information on preexisting conditions. The

Forest Service system, which includes few nontimber measures for evaluating managers, does not

encourage monitoring.

Option 6: Separate the monitoring function.

Congress could establish monitoring of forest

plans as a separate Forest Service activity, with

specified purposes and reporting.

Monitoring is important to determine whether

proposed and ongoing management activities are

consistent with planning goals. Currently no sanctions exist for incomplete or inadequate monitoring.
—

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

Congress could establish monitoring as a distinct

Forest Service responsibility. Congress could then

require an annual monitoring report, prepared by an

interdisciplinary team, with specific requirements

and with public participation or review. This would

recognize the importance of monitoring, and might

reduce the tendency to curtail or eliminate monitoring due to insufficient time or money.

Option 7: Require linkage between actions and

results.

Congress could require the Forest Service to

identify, in an annual report for each national

forest, the results of activities in terms of outputs

and conditions and in public participation in the

planning process.

An annual report from each forest could be an

added requirement under the NFMA planning process. This report could be used internally, for

evaluating the performance of forest supervisors and

staff, and externally, for informing the public about

the results of management practices. The report

could show how management activities meet output

and condition targets specified in the plans and could

also include an evaluation of public participation.

Option 8: Require public involvement in monitoring.

Congress could direct the Forest Service to

include public participation in the monitoring of

national forest plan activities.

Monitoring is expensive but essential in forest

planning. It assures that activities conform with plan

direction and achieve the plan goals. Public involvement provides feedback to the agency on how the

public interprets the plan’s direction. Public involvement also can help the agency focus on key

concerns so that the most important outputs and

conditions are measured carefully. Finally, public

involvement in monitoring can provide checks and

balances to assure that measurement is accurate.

Finding 3: Budget decisions overwhelm planning

decisions.

The annual Forest Service budget request and

appropriations from Congress are inconsistent with

the budget levels and mixes assumed in national

forest planning. This occurs, in part, because the

forest plans set up an integrated approach to land and

resource management whereas the budget request

and appropriations are arranged by resource activity.

Forest plan budgets and annual appropriations also

differ because budget assumptions vary in the

amount of restrictions. When congressional appropriations conflict with forest plan direction, the

former usually directs the course of action because

Forest Service employees are responsible for assuring that money is spent as directed. Special accounts

and trust funds, which result largely from timber

activities, encourage the emphasis on timber outputs

by providing counties and the agency with benefits

from increased timber sales. Many special accounts

and trust funds are permanently appropriated, and

receive little attention from Congress.

Option 9: Eliminate appropriations by resource.

Congress could replace appropriations by resource line item with appropriations by management activity. Congress could then direct the

Forest Service to develop its budget based on the

activities needed to implement the forest plans.

Forest Service budget requests and congressional

appropriations are now arranged in about 60 line

items, specifying expenditures for resource activities. Proposed funding for each activity is adjusted

at each budget step-by the Washington Office of

the Forest Service, the Secretary of Agriculture, the

Office of Management and Budget, and the House

and Senate Committees on Appropriations. Resourceoriented appropriations encourage the administration and Congress to specify output targets, especially for timber, because such targets are easily

specified and are controllable by Forest Service

managers. The Forest Service gives monitoring a

low priority because monitoring does not provide

tangible outputs for which the managers can be

rewarded and because the agency lacks penalties for

inadequate monitoring. Congress could replace resource appropriations with appropriations for the

activities necessary for managing the national forests—

planning, implementation, and monitoring.

Option 10: Require realistic budgets in forest

plans.

Congress could direct the Forest Service to

include a range of budget possibilities, from the

current forest budget to an unlimited increase, in the

final plan for each national forest. The Washington

Office of the Forest Service provided no direction on
Chapter 1--Summary ● 13

the budget assumptions to be used in national forest

planning. Some regions restricted budgets that

forests could assume in planning, whereas other

regions provided no restrictions. Budget restrictions

are more likely to result in forest plans that are

implementable but discourage identifying opportunities for improvement. Unrestricted budgets may

specify opportunities for investments but may produce plans that are not realistic and cannot be

implemented. Congress could require the Forest

Service to include both types of information in forest

plans. The agency could then link the forest plans

with opportunity analysis in the RPA process and

provide information on likely outputs and conditions

in the annual budget request.

Option 11: Control special accounts and trust

funds.

Congress could require more complete reporting on the sources and uses of money in the

various special accounts and trust funds, and

could clarify the purposes for which the funds

could be used.

The Forest Service presents little information on

the sources and uses of money in the various special

accounts and trust funds that provide about one third

of its budget annually. Thus, Congress is unable to

exercise much control over their use. Congress could

require the Forest Service to present more complete

information on the sources and uses of money in the

major special accounts and trust funds in the budget

request, the RPA Program, the forest plans, and the

annual reports. Congress could examine the use of

special accounts and trusts funds and clarify the

purposes for which the funds could be used.

Option 12: Compensate counties fairly and consistently.

Congress could replace the current program of

returning 25 percent of gross Forest Service

receipts with a system to compensate counties

fairly for the tax exempt status of Federal lands

and activities.

Since 1908, the Forest Service has returned 25

percent of its receipts to the States for use on roads

and schools in counties where national forests are

located. The Payments in Lieu of Taxes (PILT)

program, administered by the Bureau of Land

Management, also compensates counties for the tax

exempt status of Federal lands. It is unclear whether

the combination of Forest Service receipt-sharing

and PILT payments is fair compensation. In some

areas, the counties may receive payments that

exceed potential collections from a private owner of

undeveloped land. In other areas, the counties may

be undercompensated.

Many counties rely on Forest Service timber

harvests for large portions of their budgets, but

timber receipts may vary by as much as 50 percent

or more from year to year. Furthermore, PILT

payments require annual appropriations that could

face reductions with Federal budget cuts. Congress

could replace the current system of receipt-sharing

and PILT payments with a system that fairly and

consistently compensates the counties for the tax

exempt status of national forest lands. Congress

could require a study to devise the appropriate

compensation methods and levels, and then replace

the current system with the new tax-equivalency

compensation system.

Finding 4: National targets can nullify local

decisions.

RPA established a national strategic planning

process for renewable resources. RPA also established a local planning process for preparing land

and resource management plans for national forests.

NFMA amended RPA to include considerations and

requirements for local planning. The Forest Service

describes the connection between RPA and NFMA

as iterative, with information on capabilities and

opportunities flowing from the local level to the

national level, and national targets being allocated

from the national level to the forests. The allocation

of national RPA targets to the forests can negate

local agreement about the proper management

direction for a national forest. Nationally determined

targets also can substantially alter national forest

management directions that have been determined

with considerable local analysis and public involvement.

Option 13: Specify forest plans as the baseline for

RPA planning.

Congress could require the Forest Service to

use the management direction established in the

forest plans as the baseline for National Forest

System outputs and values in the RPA planning

process.
14 ● Forest Service Planning: Accommodating Uses, Producing Outputs, and Sustaining Ecosystems

National analyses of management options may

not account for site-specific interactions and constraints and, thus, can overestimate production

possibilities on the national forests. To correct this,

Congress could direct the Forest Service to use

national forest plans as the baseline for outputs and

values and specify that RPA Program direction be

consistent with the forest plans.

Option 14: Require RPA direction for all resources and all branches.

Congress could require the Forest Service to

provide targets and national direction for all

outputs and values and for all branches of the

agency.

The RPA Program has traditionally established

physical output targets for the National Forest

System, with only general direction for other values

and other branches of the agency. Congress could

improve the balance among resources and among

Federal and non-Federal lands by directing the

Forest Service to establish direction for agency

programs to address all outputs and values on all

forests and rangelands. Congress could require RPA

Program direction for all four branches of

the Forest Service, to be defined in long-term

goals for productivity and ecosystem health and in

short-term targets for outputs and conditions of

concern.
Chapter 2

Policy Options
. —.. - — - -. . - -- -— — -

Contents

Page

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 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . .

17

18

21

21

23

24

27

27

29
Chapter 2

Policy Options

The National Forest Management Act (NFMA)

was enacted in 1976 primarily in response to

successful lawsuits challenging longstanding Forest

Service timber sale practices in West Virginia and

elsewhere. Because these lawsuits indicated a growing public dissatisfaction with clearcutting and other

Forest Service activities, Congress chose to require

a public planning process for setting management

direction for each national forest. Congress expected

that a planning process based on sound information,

environmental standards, and public involvement

could resolve many local controversies over national

forest management.

Many are concerned that the NFMA planning

process is not working as it was intended. Forest

planning has been controversial, and nearly all forest

plans and many actions under those plans (especially

timber sales) have been appealed. Litigation, notably over red-cockaded woodpeckers in the South and

over spotted owls and old-growth forests in the

Pacific Northwest, has focused nationwide attention

on national forest management.

The current controversies over national forest

planning and management have led some, including

Members of Congress, to question the efficacy of the

planning process, and a few agency critics have

suggested repealing the requirement for forest plans.

However, plans are necessary for coordinating

activities, and the public is interested in national

forest management. Repealing the requirement for a

public planning process probably would return the

Forest Service to a situation akin to that which led to

the Monongahela lawsuit, the Bitterroot controversy, and other conflicts that led to NFMA in the

first place.

No simple means exist for ending the conflicts

over national forest management, because people

care about the national forests and have different

opinions on how the forests should be managed.

Nonetheless, the planning process could be modified

to reduce the nationwide conflicts by improving the

process for resolving local differences. OTA has

found problems and potential for improvements in

forest plan development, in forest plan implementation, in Forest Service budgeting, and in forest

planning direction. Singly and in combinations,

these options could move national forest planning

toward the goal Congress envisioned in NFMA--a

strategic planning process for developing and implementing publicly acceptable management direction

for the national forests.

FOREST PLAN DEVELOPMEN T

Finding 1: Emphasis on Timber and Other Physical Outputs

The Forest Service emphasizes allocating lands

and producing physical outputs, especially timber,

in national forest planning. Certainly outputs are

important. The forest reserves (national forests)

were established to provide stable water flows and

continuous timber supplies while protecting the

lands 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. However, the ecosystems are the investment that generate

the annuities; and their sustainability is paramount.

Forest planning today gives relatively little attention to sustaining ecosystems. Emphasis on measuring and producing physical outputs must be balanced with the nonphysical ‘‘outputs"—the nonuse

values of forests, such as spiritual appreciation or

preserving a legacy for future generations. Planning

generally provides for nonuse values through land

allocations-recommendations for wilderness and

identification of lands not suited for timber production--

but such allocations are indirect measures that divide

interests and ignore mutual benefits. The relative

inattention to sustaining ecosystems and to providing nonuse values, the increasing demand for all

resources, and conflicting social values are at least

some of the reasons for the acrimony over national

forest planning.

The emphasis on timber and other physical

outputs results from a wide variety of factors

throughout the Forest Service’s planning and management systems. (This is not to say that timber

dominates the management of all national forests,

but that the agency’s structure and programs systematically accentuate timber and other physical outputs

over other values.) The Multiple-Use SustainedYield Act of 1960 (MUSYA) implied such a focus

on outputs. Likewise, NFMA focused more on

–17–
18 ● Forest Service Planning: Accommodating Uses, Producing Outputs, and Sustaining Ecosystems

regulating timber management than other activities.

It is easier to inventory timber than to inventory

other resource conditions and values. In addition, the

principal planning technology--FORPLAN--was

developed from a timber harvesting scheduling

model, and the goal (objective function) of the

model is to maximize those outputs that can be

quantified. Other aspects of planning and management—

implementation, budgeting, and national direction—

also emphasize the quantitative, physical outputs of

the national forests.

Plan Development Options

Implementable national forest plans will necessarily include a balance of uses, outputs, and nonuse

values, with management that is sensitive to ecosystems and acceptable to the public. The current

systematic emphasis on timber and other physical

outputs makes the development of acceptable forest

plans difficult, at best, as suggested by the difficulties the Forest Service encountered in preparing the

first round of forest plans. A number of steps could

be taken to assist in achieving the balance necessary

to develop acceptable plans.

Option 1: Clarify the legislative direction.

Congress could amend the laws guiding

national forest planning and management to

recognize the nonuse values of the national

forests and to assure the long-run productivity

of the ecosystems that generate the use and

nonuse values.

Several laws guiding planning and management

of the national forests contribute to emphasis on

physical outputs. The 1897 Forest Service Organic

Act notably is not a problem. The frost purpose it

identified for the forest reserves was to improve and

protect the forests, and the second was to secure

favorable water flows--a nonuse value of the forests

(although water also has value in use). The Organic

Act also authorized regulation of the occupancy and

use of the forests ‘‘to preserve the forests . . . from

destruction. Thus, the Organic Act is fully consistent with the trust-fired concept of the national

forests—to provide use and nonuse values and to

protect the ecosystem base.

The Multiple-Use Sustained-Yield Act of 1960,

however, does contribute to the physical output

focus. MUSYA promotes the utilitarian view of

national forests, listing as purposes either direct,

on-site activities (e.g., recreation and timber) or

surrogates for such activities (e.g., range, watershed,

and wildlife and fish). Nonuse values, such as

aesthetics, spiritual appeal, and future legacies are,

at most, implicit in the act. Furthermore, sustained

yield contributes to this focus on the direct, on-site

uses and outputs by emphasizing their continued

production, rather than emphasizing the management of the ecosystems that generate all forest

values. Amendments to MUSYA could; 1) expand

the purposes of the National Forest System to that of

providing all the use and nonuse values of forests

and rangelands; 2) expand multiple-use management to include the multiple values of the lands; and

3) focus on the sustainability of the ecosystems that

comprise the national forests.

NFMA has also contributed to the timber focus by

providing additional regulatory guidance for continued timber production while protecting other values.

Section 6(k) requires the Forest Service to identify

lands not suited for producing timber, “considering

physical, economic, and other pertinent factors to

the extent feasible.’ Section 6(l)(1) requires representative information comparing timber sale, reforestation, and stand improvement costs with returns

to the Treasury. Section 13(a) requires the Forest

Service to identify the allowable sale quantity for

timber, such that the production can be sustained in

perpetuity. However, other resource management

activities are not subject to comparably restrictive

provisions. Amendments to NFMA could require:

1) equivalent determinations of land suitability for

all management activities; 2) revenue-cost comparisons for each resource; and 3) goals for sustaining all

outputs (including nonuse values) at levels which

will not decline.

Option 2: Broaden the information base.

Congress could require the Forest Service to

expand its inventory and analytical base for

forest planning to include necessary information and models on all resources, on ecological

interactions, and on social and economic impacts.

NFMA planning has been conducted with few

supplemental inventories, beyond those already in

use in forest planning and management prior to

NFMA. For example, the northern spotted owl was

identified as a management indicator species for

forest planning in western Washington and Oregon
Chapter 2-Policy Options . 19

in the early 1980s. However, the comprehensive

inventory of owl populations and habitat was not

begun until 1989, after the owl had been proposed

for listing under the Endangered Species Act and

after draft plans had been completed for many of the

forests. The Forest Service has been conducting

timber inventories for many years, with substantial

statistical validity, and has numerous models for

examining future stand conditions and related outputs based on current or proposed management

activities. However, inventories for other resources

and for ecosystem conditions are less complete and

models are less fully developed. Similarly, the data

and models for examining the economic consequences of management activities are more complete for timber outputs than for other outputs and

conditions.

This is not to suggest that better data on resources,

conditions, and trends will allow for correct, scientific management of the national forests. Forest

planning is necessarily political, because the decisions and choices are about the future and what it

should look like. Furthermore, information is expensive, and some data will always be imprecise.

However, improved information and models can

more accurately describe the current situation and

how actions are likely to affect future outputs and

conditions. This is as true for the economic and

social effects of decisions as it is for the ecological

aspects of land management. Information and models should also focus on public values-on outputs,

conditions, jobs, the legacy we leave to the future,

etc. Thus, public participation should help define

what should be measured and what analytical tools

are needed for forest planning.

Congress has provided little direction to the

Forest Service on the kind of information required

for forest planning and how to obtain it. NFMA

established a number of analytical requirements,

such as identifying lands not suited for timber

production and determining the allowable timber

sale level that could be sustained in perpetuity,

which dictate certain analytical tools. However,

NFMA contained no specific requirements on inventories; it only required the regulations to ‘‘provide

for obtaining inventory data. ” Some analyses are

implied by the various requirements, such as providing for biological diversity and prohibiting irreversible watershed damage. Congress has protected the

Forest Service from judicial challenge to plans

developed using inadequate, outdated information

through a rider on the Forest Service appropriations

for fiscal years 1988 and 1989.

Congress could direct the Forest Service to

improve its inventory and analytical base for forest

planning, to assure that the information and analysis

responds to the public’s concerns in terms of

national forest goals and direction, of opportunities

and tradeoffs, and of management practices. Congress might also recognize the cost of acquiring

additional information, since new inventories and

tools can be expensive to develop, and a simple

requirement for ‘‘adequate’ information could be

subject to widely disparate interpretations. Some

congressional guidance on the nature and purpose of

information and analysis could assist the agency in

determining, and the courts in assessing, the adequacy of the inventory and analytical base.

Option 3: Establish targets for all resources.

Congress could require the forest plans to

specify targets for all resource uses and outputs, nonuse values, and ecosystem conditions

identified as important by the public in its

participation in the planning process.

Congress intended the forest plans to set the

direction for managing the national forests. Direction is, in part, described by the established shortand long-term goals. However, as discussed above,

the information base and analytical tools emphasize

physical outputs, and are fragmentary at best for

nonuse values and for ecosystem conditions. While

the public is interested in physical outputs, it is also

concerned about nonuse values and about the

long-term health of ecosystems. The emphasis on

outputs contributes to conflicts over national forest

planning, because the public wants goals established

for all the uses and values of the forests and

rangelands,

Congress could require the Forest Service to

describe more fully the management direction for

the national forests by identifying targets for uses

and outputs, for nonuse values, and for ecosystem

conditions in the forest plans. Identifying such

targets will require development of relevant measures, especially for nonuse values and ecosystem

conditions. Such an expanded information base

might not be immediately implementable. Nonetheless, a broad array of targets is necessary to respond

to 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 for

involving the public in forest planning, and

could direct the Forest Service to improve its

public participation processes.

Effective public participation in forest planning

demands that the agency and the participants understand why participation is required. NFMA and the

National Environmental Policy Act of 1969 (NEPA)

helped to establish public involvement in agency

planning and decisionmaking. However, the language in the laws requiring public participation in

forest planning is ambiguous as to why the public

should be involved. Therefore the agency and the

public have differing and even opposing expectations about how public comments are to be considered and used in determining the future direction of

national forest management. The imprecise guidance and contrasting expectations have heightened

the conflict over national forest planning and management.

The Forest Service model of public participation

also has hindered effective public involvement in

forest planning. Many Forest Service managers

approach public participation as an ‘‘inform and

educate’ exercise--to learn what the various interests want and to inform them of what is feasible. This

approach impedes effective participation, because

the public is viewed merely as a source for establishing output goals, rather than as individuals and

groups interested in all aspects of management. It

also suppresses understanding and trust, because the

individuals and groups are supposed to accept what

the Forest Service determines is feasible, even

though the information presented is often incomplete or too technical for many to comprehend.

Furthermore, the agency often addresses the interests separately, which can lead to mistrust about

what agreements have already been reached. Thus,

the ‘inform-and-educate model and meetings with

separate groups hamper effective public participation in forest planning.

Congress could clarify the purpose for public

participation in forest planning. NFMA could be

amended to direct the Forest Service to use public

involvement to build plans and decisions that are

acceptable. Various tools could be employed, to

assure effective involvement by the variety of

individuals and groups interested in forest planning

and management, including but not limited to formal

and informal public gatherings, personal contacts,

and alternative dispute resolution techniques. Congress could also strengthen the direction in section

14 of the Forest and Rangeland Renewable Resources Planning Act (RPA), as amended by NFMA,

for using advisory committees, including an exemption from the Federal Advisory Committee Act, if

deemed appropriate.

The Forest Service could also improve its public

participation process by stressing the importance of

building trust and consensus (or at least not opposition) among the various interests. The Forest Service

recognizes the widespread dissatisfaction with the

current process, and currently has an employee

training course that seems to build on this concept of

public involvement. Nonetheless, the Forest Service

must assure the public and its employees that the

process is intended to build local agreement on how

the national forests should be managed.

Option 5: Expand use of information technologies.

Congress could direct the Forest Service to

broaden the variety of technologies used for

information collection, analysis, coordination,

and presentation to be sure that both spatial

and temporal aspects of forest management

are adequately addressed.

The Forest Service, in 1979, designated

FORPLAN as its principal tool for national forest

planning. FORPLAN (and linear programming in

general) is useful for organizing data and analyzing the temporal aspects of forest outputs, but

FORPLAN: 1) typically requires information on

resource interactions that exceed the state-of-theknowledge, 2) has limited capacity for analyzing

spatial concerns, and 3) was built to be comprehensive- - answer all relevant questions in one model—

and thus often defies understanding by the public

and even planners. IMPLAN (and input-output

models in general) is useful for ex amining the

economic consequences of plan alternatives, but the

nature of the data and the model lead to a fuller

picture of the impacts on the timber industry than on

other industries.

Congress could direct the Forest Service to

improve its use of various planning technologies.

FORPLAN, or a comparable tool, is probably

necessary to address temporal concerns, such as

sustainable output levels, but could be simplified by
Chapter 2-Policy Options ● 21

separating distinct issues for analysis with different

versions of the model. Despite the extreme cost of

geographic information systems, such a spatial tool

is probably necessary to address spatial concerns,

and would be most useful if linked to FORPLAN.

The Forest Service could also be directed to emphasize research on models for spatial and temporal

resource interactions and on more complete models

of economic and social impacts. The Forest Service

could be directed to improve the coordination of data

collection and storage, to build a historical record for

forest planning and to contribute to an integrated

Renewable Resource Assessment. Finally, the Forest Service must recognize that the various technologies are intended to support and assist in building

acceptable plans and decisions, not to provide a

definitive answer that must simply be accepted.

FOREST PLA N

IMPLEMENTATIO N

Finding 2: Monitoring of Forest Management

Activities Is Inadequate

National forest plans have been developed with

enormous expenditures of Federal and public time

and effort, but it is uncertain how effectively those

plans are being implemented. To date, monitoring

has been inadequate to evaluate national forest

planning and management.

The inadequate monitoring results, in part, from

the inadequate base of information on resource uses

and outputs and ecosystem conditions of forests and

rangelands. For example, it is impossible to monitor

changes in ecosystem conditions that result from

forest planning direction or from management activities without baseline information on preexisting

conditions. On the other hand, monitoring could

help establish baseline data needed for forest planning. Thus, inadequate inventories and inadequate

monitoring are part-and-parcel of the same problem,

and both must be improved to provide an adequate

picture of the forest and rangeland resources and

ecosystems.

Inadequate monitoring also results from the lack

of incentives to monitor, or more precisely, from the

lack of penalties for not monitoring. Forest supervisors are evaluated largely on achieving the easily

measurable annual outputs specified for their forests—

the “hard’ targets, such as timber sale targets-and

on spending money as appropriated. Timber sale

outputs and expenditures are important, but the lack

of monitoring of other plan objectives permits

achieving other activities and goals to be postponed

and could allow resource and ecosystem conditions

to deteriorate. Monitoring that shows degrading

conditions or unbalanced achievement of plan objectives would not only reflect poorly on the agency

and its managers, but would also provide the public

with information that could be used to challenge

activities and practices. Thus, the agency has a

distinct disincentive to monitor the implementation

of the forest plans.

Plan Implementation Options

Monitoring is an essential part of strategic planning for the national forests. Monitoring serves three

purposes. First, monitoring demonstrates whether

the management activities on the ground are consistent with the direction established in the forest plan.

Second, monitoring demonstrates if the results of

those activities achieve the goals identified in the

plan. And third, monitoring demonstrates the accuracy of the assumptions and values used in the plan.

Through such demonstrations, monitoring provides

the feedback needed to revise the plans and management activities and to assure that the national forests

are being managed to meet the needs of the

American people. Several options could improve

monitoring of forest plan implementation.

Option 6: Separate the monitoring function.

Congress could establish monitoring of forest plans as a separate Forest Service activity,

with specified purposes and reporting.

Current Forest Service planning regulations (36

CFR 219.1 l(d)) specify that the forest plans must

identify the monitoring and evaluation requirements

needed to evaluate management activities. While the

plans all appear to contain monitoring sections, no

sanctions exist for incomplete or inadequate monitoring. Furthermore, monitoring and reporting might

demonstrate that activities are inconsistent with the

direction established in the plan, that the outputs

vary from the planned goals, or that the assumptions

upon which the plan is based are incorrect. In

addition, monitoring must compete for funding with

other activities, such as planning and output production. Thus, monitoring is generally the first activity

to be eliminated or reduced when funding is less than

the level specified in the forest plan.
22 ● Forest Service Planning: Accommodating Uses, Producing Outputs, and Sustaining Ecosystems

Congress could establish monitoring and reporting as a distinct Forest Service responsibility, much

as it did with integrated land and resource management planning. The Forest Service had conducted

planning before the enactment of RPA and NFMA,

but Congress specified standards for national forest

planning, such as an interdisciplinary approach,

periodic revisions, specific considerations, and public participation. Congress similarly could require an

annual monitoring report, prepared by an interdisciplinary team, with specific requirements and public

participation. (The following options discuss these

latter aspects.) This would recognize the importance

of monitoring, and might reduce the likelihood of

Curtailing “ “ or eliminating monitoring due to insufficient time or money.

Option 7: Require linkage between actions and

results.

Congress could require the Forest Service to

identify, in an annual report for each national

forest, the results of activities in terms of the

outputs and conditions identified as goals in

the national forest plans, and in terms of public

participation in the planning process.

The Forest Service currently is required to prepare

a national annual report on its activities as part of the

RPA planning process. However, as described in the

OTA study, Forest Service Planning: Setting Strategic Direction Under RPA, the agency’s annual

report provides an incomplete picture of outputs and

condition changes in the national forests. Timber

sales and harvests, recreation use, and other uses and

outputs are often identified, but the measures for

some resources are merely rough estimates. The

report more typically identifies management activities, but the activities are not related to the conditions supposedly being managed; for example,

range, watershed, and wildlife habitat improvement

efforts are reported, but the agency lacks measures

(quantitative or qualitative) to show the resulting

improvements in range condition, watershed condition, or wildlife habitat condition.

Comparable annual reports are not required as

part of NFMA planning, although many forests

produce them and the Forest Service has recently

proposed annual reports for each national forest. An

annual report could be useful internally, for evaluating the performance of forest supervisors and their

staffs, and externally, for informing the public about

the results of management. However, to be effective

for such uses, an annual report must demonstrate

how on-the-ground activities meet the output and

condition targets specified in the forest plans.

Because of concerns about the community impacts

of national forest management, an annua1 report

might also identify relevant changes in local employment that result from management activities.

An annual report on national forest management

could also include an evaluation of public participation. Some have suggested that managers should be

rewarded for resolving administrative appeals and

lawsuits over forest plans and over activities to

implement the plans. Resolving issues locally is

generally desirable, and a declining number of

appeals and lawsuits would indicate success in such

efforts. However, some conflicts cannot be resolved

locally, while others may be reduced by postponing

decisions or by directing the decision to another

forum. Thus, additional measures of effective local

public involvement in forest planning and management are needed to evaluate fully managerial performance in public participation responsibilities.

Congress could require an annual report from

each national forest to provide relevant information

for internal and external reviews that would complete the feedback necessary for strategic national

forest planning under NFMA. Measures for comparing annual performance with output and condition

targets identified in the plan could be required, and

reporting on the local economic impacts of management and on public involvement could also be

specified.

Option 8: Require public involvement in monitoring.

Congress could direct the Forest Service to

include public participation in the monitoring

of forest plan activities.

The public is interested in national forest management, is involved in national forest planning, and is

concerned about the results of management activities. Simply reporting on results is feasible, but

places the public on the outside, rather than making

them participants in planning and management.

Congress could specify that the Forest Service

include public participation in the monitoring of

forest plan activities.
Chapter 2--Policy Options . 23

Including the public in monitoring could fulfill

several purposes. As described above, monitoring

assures that activities conform with the direction in

the plan. However, different individuals can read the

same statements describing direction, and reach

different conclusions about what activities are consistent with that direction. Public involvement in

monitoring provides feedback to the agency on how

the public interprets the plan’s direction. Significant

differences in interpretation would suggest that a

plan needs to specify the management direction

more clearly.

Monitoring is also intended to assess whether the

results of activities achieve the goals identified in the

plan. Public participation in monitoring can help

assure that the Forest Service focuses on the outputs,

sites, and other values that are important to various

interests. Monitoring all results of management

activities on all sites is expensive, time-consuming,

and probably impossible in a practical sense. Thus,

monitoring is necessarily limited. Involving the

public can assist the agency to focus on the key

concerns, to guarantee that the most important

outputs and conditions are measured most carefully.

Finally, public involvement in monitoring can

also save money. Many individuals and groups who

participate in planning have expertise that could be

used to conduct some monitoring activities. Having

a variety of interests involved can provide a balance

of views and checks to assure that measurements are

comprehensive and accurate. In this way, the Forest

Service can build trust between the employees and

the public, and among the disparate stakeholders in

national forest planning and management. However,

Forest Service managers must still be responsible for

measuring the results of activities in the national

forests and for implementing the forest plans.

FOREST SERVICE BUDGE T

RECONCILIATIO N

Finding 3: Budget Decisions Overwhelm Planning

Decisions

The annual Forest Service budget request and the

subsequent appropriations from Congress are inconsistent with the budget levels and mixes assumed in

national forest planning. This occurs, in part, because the forest plans establish an integrated,

coordinated approach to land and resource management, but the budget request and appropriations are

arranged by resource activity. Budgets for multipleuse management at the forests must be translated

into resource-oriented budgets, and these resource

budgets are then modified by the Washington Office

of the Forest Service, the Secretary of Agriculture,

the Office of Management and Budget, and the

House and Senate Committees on Appropriations to

meet their political needs and responsibilities. The

result is congressional appropriations that bear little

resemblance to the coordinated budgets needed to

implement the integrated land and resource management plans.

The difference between forest plan budgets and

annual appropriations also results from the variety of

budget assumptions used in forest planning. One

regional office restricted the budget increases which

could be assumed in forest planning, but others

permitted unrestricted and often unrealistic budget

increases to achieve all the goals desired by the

public. Such plans can seem ideal to the public, so

long as no one is clearly responsible for paying for

the plan. The differences in budget assumptions in

forest planning prevent the Forest Service from

developing a budget request directly from the forest

plans.

When congressional appropriations conflict with

forest plan directions, the budget decision is invariably followed, because Forest Service employees are

responsible (some are personally liable) for assuring

that money is spent as Congress directs. Thus,

appropriations by resource activity-not the forest

plans-essentially control the management activities in the national forests. Furthermore, the annual

appropriations have specified Forest Service timber

sale targets, typically in excess of the administration’s request (although below the potential identified in forest plans with unrestricted budgets), and

these congressional timber targets determine national, and ultimately local, management priorities.

The appropriations have not included targets for

other resource outputs or for resource conditions

and, thus, have contributed to the Forest Service’s

emphasis on timber outputs. (See ‘‘Finding 1:

Emphasis on Timber and Other Physical Outputs. ’

Finally, the Forest Service has a number of special

accounts and trust funds, comprising about a third of

the Forest Service budget. The largest is Forest

Service receipt-sharing payments to counties, with

payments often exceeding $300 million annually.

However, the Knutson-Vandenberg (K-V) Fund, the
24 ● Forest Service Planning: Accommodating Uses, Producing Outputs, and Sustaining Ecosystems

Timber Salvage Sale Fund, brush disposal, and other

special accounts and trust funds generate at least

$500 million annually for Forest Service activities.

These funds result mostly from timber harvests, but

the expenditures commonly are not limited to timber

sales or investments. Thus, the counties (through the

receipt-sharing payments) and the managers of most

resource programs (through available budgets) benefit from increasing timber sales, again contributing

to the emphasis on timber outputs. Furthermore,

many of these special accounts and trust funds are

permanently appropriated, with the money automatically available unless Congress halts or restricts the

expenditures. Congress has given relatively little

attention to these funding sources, and their use has

become increasingly important as the Federal budget

problems have mounted.

Forest Service Budget Options

If the forest plans are to be implemented, the

planning process must be integrated with the budget

and appropriations process. The budget process

must provide balanced consideration of all the

resource output and condition goals of the forest

plans. Congress needs information on the opportunities for improving management with additional

funding, but Congress and the public also need to

know how the forests will be managed if the desired

funds are not available. Furthermore, the Forest

Service needs flexibility to implement the forest

plans, but Congress needs to exercise its control to

assure that national forest management fits within

the overall spending and taxing priorities demanded

by the public. Congress has several options for

integrating and balancing the planning and budgeting processes and for providing the necessary

flexibility while retaining appropriate control.

Option 9: Eliminate appropriations by resource.

Congress could appropriate funds by management activity, rather than by resource line

items, and direct the Forest Service to develop

its budget accordingly, based on the activities

needed for implementing the forest plans.

Forest Service budget requests and congressional

appropriations are currently arranged in about 60

line items, specifying expenditures for various

resource activities, such as timber sale preparation

and administration, wildlife habitat improvement,

and trail maintenance. Proposed funding for each

resource activity is adjusted at each step in the

budget process—by the Washington Office of the

Forest Service, the Secretary of Agriculture, the

Office of Management and Budget, and the House

and Senate Committees on Appropriations-to meet

their own needs and responsibilities. The eventual

appropriations by resource rarely mesh with the

funding needed for integrated, multiple-use management under the forest plans. Furthermore, the

resource-oriented appropriations also encourage the

administration and Congress to specify output targets, especially for timber, since timber targets are

easily specified and are more controllable by Forest

Service managers.

A related problem is that, under resource-oriented

appropriations, other necessary activities are either

unfunded or must be conducted with funds intended

for resource management. Planning, and the requisite training and software development and acquisition, has been funded largely by resource-specific

appropriations. Monitoring is typically conducted

by the resource specialists for the resource being

monitored, but does not provide tangible results for

which the resource managers can be rewarded.

When combined with the lack of penalties for

inadequate monitoring, it is not surprising that

monitoring has a low priority within the agency.

Thus, although planning and monitoring are essential to effective national forest management, funding

for these activities must be diverted from the various

resource activity appropriations.

Congress could replace the resource-oriented

appropriations with appropriations for the activities

necessary for managing the national forests—

planning, implementing, and monitoring. These

major categories could be further subdivided, to

provide Congress with more control over the agency’s

budget. For example, planning could be divided into

inventories and data management, technology acquisition and development, personnel development,

public involvement, and plan preparation (writing

and reproducing). Similarly, monitoring could be

divided into on-site measurement, equipment purchases, personnel development, public involvement,

and report preparation. Implementation could be

subdivided into ongoing activities and investments,

with ongoing activities including use and output

production and control, and maintaining current

resource, ecosystem, and facility conditions. Investment categories could include roads, trails, and

facilities to increase or control uses and outputs, and
—— .

Chapter 2----Policy Options ● 25

administrative facilities. Resource, ecosystem, and

facility rehabilitation to improve current conditions,

such as reforestation or trail reconstruction, could be

identified as either ongoing activities or as investments.

Reorganizing the Forest Service budget would not

eliminate the agency’s responsibility to provide

information on the anticipated uses and outputs and

on the likely changes in resource, ecosystem, and

facility conditions at the requested budget level (and

with increases or decreases in the budget). The

Forest Service could also be required to provide unit

cost information for important activities, such as

successful reforestation, road construction, and recreation facility operation. Nonetheless, such reorganization of the budget and appropriations structure could allow Congress to retain control over

important decisions (e.g., the level and location of

investments), could assure adequate funding for

necessary activities (e.g., planning and monitoring),

and could provide the Forest Service with the

flexibility to implement the forest plans,

Option 10: Require realistic budgets in forest

plans.

Congress could direct the Forest Service to

include a range of budget possibilities, from

the current forest budget to an unlimited

increase, in the final plan for each national

forest.

The Washington Office of the Forest Service

provided no direction on the budget assumptions to

be used in national forest planning. One region

restricted the budgets that forests could assume in

planning but most did not. Budget restrictions are

more likely to result in forest plans that are

implementable, i.e., within the realities of Federal

budget limitations. However, such restrictions also

prevent the forests from identifying opportunities for

improving national forest management and for

generating additional revenues through increased

budgets. This has placed forests with restricted

budget assumptions at a disadvantage in annual

internal budget negotiations.

While unrestricted budget assumptions have allowed forest and regional personnel to identify

opportunities for investments under increased budgets and are more acceptable to the public (because

more uses and outputs can be accommodated while

maintaining or improving resource and ecosystem

conditions), such forest plans may be unimplementable. Conditions may deteriorate and/or the

uses and outputs must be at lower levels than

planned, increasing the likelihood of challenges in

administrative appeals or litigation.

Both types of information---+pportunities with

unrestricted budgets and likely management with

budget limitations-are necessary in forest planning. Unrestricted budget opportunities are important to demonstrate how management could be

improved, and an analysis of opportunities is required in the RPA Assessment. However, the

administration and Congress are facing increasing

pressures to reduce the Federal budget and, thus,

substantial budget increases are unlikely. Congress

and the public need to know how the forests are

likely to be managed under limited budgets. Congress could require the Forest Service to include

both types of information in forest plans, thereby

linking the forest plans with opportunity analysis in

the RPA process and providing information on the

likely management direction and the near-term

outputs and conditions in the national forests.

Option 11: Control special accounts and trust

funds.

Congress could require more complete reporting on the sources and uses of money in the

various special accounts and trust funds, and

could clarify the purposes for which the funds

could be used.

The Forest Service presents little information on

the sources and uses of money in the various special

accounts and trust funds. The budget request contains aggregate information on the expected receipts

and expenditures from each fund, but with little or no

discussion of the purposes or locations of the

expenditures. The annual Report of the Forest

Service presents information on reforestation and

timber stand improvement under the K-V Fund and

on road construction and reconstruction using purchaser road credits, but not on revenue-sharing

payments, the Timber Salvage Fund, the Working

Capital Fund, brush disposal, or other permanent

appropriations. The Timber Sale Program Information Reporting System (TSPIRS) also includes K-V

Funds and purchaser road credits, and adds the

Timber Salvage Fund, but excludes brush disposal

and road maintenance deposits from timber purchasers. The forest plans, and the RPA Program, do not
26 ● Forest Service Planning: Accommodating Uses, Producing Outputs, and Sustaining Ecosystems

distinguish funding and activities under any special

accounts or trust funds.

The special accounts and trust funds provide

about a third of the Forest Service budget annually,

but with the sparse information available, Congress

is unable to exercise much oversight and control

over their use. Some have specified funding levels:

revenue-sharing is 25 percent of gross receipts, and

the Reforestation Trust Fund receives up to $30

million annually from tariffs on wood product

imports. However, deposits to most of the accounts

are at the discretion of the Forest Service at the local

level. An unlimited portion of timber receipts can be

deposited in the K-V Fund. If the Forest Service

designates a sale as a salvage sale, because it

contains some (unspecified) volume of dead, dying,

or threatened timber, the remaining timber receipts

can be deposited in the Timber Salvage Fund. The

level of brush disposal and other cooperative deposits is also at the discretion of the Forest Service.

Thus, the Forest Service has substantial local

authority to determine the amount of money deposited in the various special accounts and trust funds

if the forest has timber to sell.

The Forest Service also has substantial discretion

over the use of the special accounts and trust finds.

Several accounts (K-V, salvage, brush disposal, and

other cooperative deposits) are to be used on the

national forest that generated the deposits, although

some funds are used for regional and Washington

Office staff. Most accounts have specified purposes:

salvage funds are to prepare and administer new

salvage sales; the Reforestation Trust Fund is for

reforestation and timber stand improvement; brush

disposal and other cooperative deposits are for the

purposes specified in the contractor agreement. The

Forest Service has relatively broad discretion over

the use of the K-V Fund-it can be used for

reforesting cutover sites, for improving timber

stands, or for mitigating and enhancing other resources within the timber sale area. To date, no

studies have examined whether the level or use of

the special accounts and trust funds are consistent

with congressional intent.

Congress could require the Forest Service to

present more information on the sources and uses of

monies in the major special accounts and trust funds

in the budget request, the RPA program, the forest

plans, and the annual reports. Congress could also

examine the use of special accounts and trust funds,

through oversight hearings and/or review by the

General Accounting Office, to assess whether the

use of the funds is consistent with the original intent

and with forest planning. Congress could also clarify

the purposes for which the funds could be used, to

assure that the special accounts and trust funds are

used in a manner that is consistent with the direction

set forth in the forest plans.

Option 12: Compensate counties equitably.

Congress could replace the current program

of returning 25 percent of gross Forest Service

receipts with a system to compensate counties

fairly for the tax exempt status of Federal

lands and activities.

Since 1908, the Forest Service has returned 25

percent of its receipts to the States for use on the

roads and schools in the counties where the national

forests are located. The payments were clearly

intended to compensate the counties for the tax

exempt status of the national forest lands, but the

legislative history provides no explanation of why

compensation of 25 percent of receipts was deemed

appropriate. In 1976, NFMA expanded the definition to include K-V Fund deposits and timber

purchaser road credits as gross receipts, because the

Forest Service had been diverting an increasing

share of receipts to “internal management purposes” (reforestation and road construction), and

thereby reducing the basis for county payments.

Receipt-sharing is akin to an ad valorem severance

or yield tax, which some jurisdictions use to tax

private timberland owners. However, it is unclear

whether Forest Service receipt-sharing approximates common severance or yield tax systems, and

in some States, purchasers also pay yield taxes on

their harvests of Federal timber.

A second program, enacted in 1976, compensates

counties 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 per

acre for entitlement lands (which include most

National Forest System lands), although the total

payments are limited by the population in the

county. PILT payments are also reduced by compensation under other programs, such as Forest Service

receipt-sharing payments, to a minimum of $0.10

per acre per year. Thus, in areas where Forest Service

payments exceed $0.65 per acre, the counties receive
Chapter 2--Policy Options ● 27

$0.10 per acre under PILT and the full Forest Service

payments. In areas where Forest Service payments

are 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 in

Forest Service payments, and thus county compensation could be above or below $0.75 per acre in any

given year, but will average $0.75 per acre.) The

PILT payments have not changed since the program

was created, and thus compensation in real dollars is

currently less than half of what Congress enacted in

1976.

It is unclear whether the combination of Forest

Service receipt-sharing and Bureau of Land Management PILT payments is equitable compensation

for the tax exempt status of national forest lands. In

some areas, the counties may receive payments that

exceed what collections from a private owner of

undeveloped land might be, but in other areas, the

counties might be undercompensated. Timber generally accounts for at least 90 percent of Forest

Service receipts, and in heavily timbered areas,

Forest Service payments can be substantial. Many

counties rely on Forest Service payments for substantial portions of their budgets, but the agency

does not regulate the timing of harvests, and, thus,

receipts and county payments vary as timber harvests fluctuate. Timber receipts fluctuate widely,

rising or falling by 50 percent or more from year to

year because of changing market condition. Furthermore, PILT payments require annual appropriations

from Congress, and while Congress has not failed to

appropriate the full authorization, Federal budget

constraints could force reductions in PILT payments. Counties, therefore, must depend on unpredictable sources that might be compensating them

less than a private landowner would.

Congress could replace the current system of

receipt-sharing and PILT payments with a system

that fairly and consistently compensates the counties

for the tax exempt status of national forest lands.

Such compensation would reimburse States and

counties for lost property taxes, sales taxes, income

taxes, and/or yield taxes, depending on existing tax

structures, and the basis could vary by county or by

State. Congress could require a study, by the General

Accounting Office or some other agency, to devise

the appropriate compensation methods and levels,

and then could replace the current system with the

new tax-equivalency compensation system.

FOREST PLANNING DIRECTIO N

Finding 4: National Targets Can Nullify Local

Decisions

RPA established a national strategic planning

process for renewable resources under which the

Forest Service is to assess opportunities and capabilities, develop a long-term agency program, coordinate that program with annual budgets, and report

annually on progress in implementing that program.

RPA also established a local planning process for

preparing land and resource management plans for

the national forests, and NFMA amended RPA to

provide substantial guidance on considerations and

requirements for the local planning process. Congress may not have envisioned a close union

between the local and national plannin g processes,

but they have evolved toward closer coordination.

The Forest Service describes the connection as an

iterative process, with information on capabilities

and opportunities flowing into the RPA Assessment,

and quantitative national targets from the RPA

Program being allocated to the forests.

Allocating national RPA targets to the national

forests can negate local agreement about the appropriate management direction for a national forest.

Allocated targets may be technically infeasible,

because a comprehensive, national analysis necessarily aggregates information on local capabilities,

and loses the site-specific interactions and constraints. Furthermore, the RPA Program is subject to

national political pressures, from within the administration and from Congress and the many interest

groups, that may be insensitive to local demands and

capabilities. Thus, national goals can be infeasible to

achieve on the ground. In addition, because of

existing inventories and analytical tools, targets

focus on annual physical outputs, especially timber

outputs. Allocated timber targets from RPA (or from

the annual appropriations), even if technically feasible, can substantially alter the national forest management direction, determined with considerable

local analysis and public involvement.

Planning Direction Options

To implement national forest plans

acceptable to the public, the NFMA

that are

planning

process must be coordinated with the RPA planning

process by maintaining a continuous, multidimensional exchange of information on current situations,

297-904 0 - 92 - 2
28 ● Forest Service Planning: Accommodating Uses, Producing Outputs, and Sustaining Ecosystems

capabilities, and opportunities-including physical

and political potentials and limitations. National

direction for forest planning is needed to assure

adequate consideration of regional, national, and

global problems and concerns. However, only local

analysis can determine physically and politically

feasible solutions.

Option 13: Specify forest plans as the baseline for

RPA planning.

Congress could require the Forest Service to

use the management direction established in

the forest plans as the baseline for National

Forest System outputs and values in the RPA

planning process.

The Forest Service envisions an iterative NFMA

planning-RPA planning process, with the forest

plans providing information for the RPA Assessment and the RPA Program establishing targets for

the National Forest System. Clearly, the forest plans

can contribute data on the current situation, and on

the capabilities and opportunities for the forests to

provide outputs and other values-data which are

essential to an assessment of the renewable resource

situation in the United States. However, national

analyses of management options can overestimate

production possibilities, because site-specific interactions and constraints cannot be maintained in such

analyses. Therefore, national output targets allocated to the forests may be technically infeasible to

implement.

Alternatively, Congress could direct the Forest

Service to use national forest plans as a technically

and politically feasible baseline for outputs and

values from the National Forest System, particularly

if a consistent range of budget possibilities is

required in forest planning. Then, in RPA planning,

the Forest Service could compare the baseline

National Forest System production and the expected

private and other public production with the demand

projections, to determine likely shortfalls, unacceptable price increases, and/or deteriorating conditions.

The RPA Program could examine alternatives to

address these identified problems—by increasing

National Forest System budgets, by expanding

research, and/or by bolstering financial and technical assistance to States and to private landowners. If

regional, national, or global concerns cannot be

adequately addressed under such alternatives, the

RPA Program could provide direction for additional

issues to be considered as forest plans are revised. If

the problems are near term, the Program could direct

immediate analyses of potential plan amendments or

revisions to address the problems. However, Congress could specify that any RPA Program direction

for the National Forest System be consistent with

locally developed forest plans and with public participation to assure that the direction is acceptable.

Option 14: Require RPA direction for all resources and all branches.

Congress could require the Forest Service to

provide targets and/or national direction for

all outputs and values and for all branches of

the agency.

The RPA Program has traditionally established

physical output targets, principally because the

available information and analytical tools focus on

physical outputs. It is admittedly difficult to establish goals for values other than annual physical

outputs, particularly when the inventories and analytical models concentrate on outputs. Nonetheless,

the emphasis on physical outputs from the national

forests has impeded consideration of ecosystem

sustainability.

The RPA Program has also focused on the

National Forest System. The Program typically sets

the direction for Research and State and Private

Forestry by simply extending and expanding the size

and structure of current activities. In contrast, targets

for the National Forest System are driven by the

desire to alleviate demand-supply imbalances for the

various resources through national forest management. This focus largely reflects the ability to hold

forest supervisors and other line managers accountable for achieving physical output targets, whereas

researchers and employees providing financial and

technical assistance are not clearly responsible for

producing outputs. However, this focus has led to an

emphasis on the National Forest System lands and

outputs, which exceeds their importance in the

Nation’s land and renewable resource base.

Congress could improve the balance among

resources and among Federal and non-Federal lands

by directing the Forest Service to establish direction

for agency programs to address all the outputs and

values on all forests and rangelands. The Forest

Service could be directed to emphasize financial and

technical assistance to alleviate regional demandsupply imbalances for marketed outputs and values,
Chapter 2-Policy Options . 29

and to focus on Federal and other government lands

for demand-supply imbalances of unmarketed outputs and values. Congress could require RPA

Program direction, for all the branches of the Forest

Service, to be defined in long-term goals for

productivity and ecosystem health and in short-term

targets for outputs and conditions of concern.

SUMMARY AND CONCLUSION S

Congress, in enacting NFMA, envisioned an open

planning process for establishing national forest

management direction acceptable to the public. To

date, national forest planning has not fulfilled this

vision, and national forest management seems to be

as controversial now as when NFMA was enacted.

Most plans and many actions under those plans have

been appealed, and lawsuits have focused national

attention on Forest Service land and resource

management. Some argue that the planning process

has become so controversial and burdensome that

NFMA should be repealed, while others have

proposed modifications emphasizing various aspects of plan implementation.

OTA found a number of problems in national

forest planning. The plans focus on producing

timber and other physical annual outputs, because of

an emphasis on outputs in the legislative guidance,

in the inventories, and in the analytical technologies.

Outputs from the national forests are clearly important, but sustaining the ecological health of the

national forests is paramount. The national forests

are, in many ways, comparable to a trust fund,

intended to produce annuities from assets. Annuities

are desirable, but maintaining and enhancing the

assets is crucial to perpetuating the annuities. In

national forest planning, inventories, analyses, and

targets too often emphasize the outputs (the annuities) and discount the ecosystems (the assets).

The focus on physical outputs could be overcome,

if the environmental and economic consequences of

planning and management were assiduously monitored. However, monitoring has been insufficient to

evaluate national forest plans and management.

Efforts to produce outputs or, in some cases, the

agency’s failure to act could be degrading the nonuse

values and the productive assets of the national

forests, but the monitoring needed to assess such

changes is not being done. Monitoring can determine: 1 ) if the activities are consistent with the

direction established in the plans; 2) if the results

accomplish the plan’s objectives; and 3) if the

assumptions and models used in the planning

process are accurate. To date, monitoring of national

forest plans and their implementation has not

achieved these purposes. The lack of monitoring

results, in part, from the inadequate information

base. More importantly, however, monitoring is

fragmentary because there are no incentives to

monitor, and no penalties for managers for not

monitoring.

Direction-setting at the national level has also

emphasized annual timber and other outputs, although better integration of forest plans in the RPA

planning process could help to protect nonuse values

and long-run ecosystem health. The resourceoriented budget process and the numerous special

accounts and trust funds (which are funded principally through timber sales) contribute to the focus on

timber and other outputs. Furthermore, RPA planning was intended to be a strategic process for all

renewable forest and rangeland resources, but has

emphasized timber and other outputs from the

national forests, again because better information

and analytical tools exist for timber and other annual

outputs than for ecosystem conditions. Unless closely

coordinated with the forest plans, national output

targets from the annual appropriations or from the

RPA planning process can overwhelm the technically and politically feasible decisions produced

locally, through substantial analysis and public

participation.

Despite these problems, NFMA planning can

fulfill the strategic process envisioned by Congress.

Clearer legislative direction, a broader information

base, targets for ecosystem health as well as for

annual outputs, more effective public participation,

and a variety of analytical technologies could lead to

technically and politically feasible national forest

plans and management. Distinguishing and organizing monitoring, linking activities to results, and

involving the public in monitoring can assure that

forest plans are implemented. Appropriations by

management activity, realistic budget assumptions

in forest plans, better accounting for special accounts and trust funds, and fair compensation to

counties for the tax exempt status of Federal lands

could lead to Federal financing consistent with the

forest plans and overall Federal budget constraints.

Finally, a more interactive RPA-NFMA planning

process, with forest plans as the baseline for the

National Forest System and with long- and short-
. . —-. . .

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

term direction for all resource values and all These changes can complete the strategic planning

branches of the agency, can result in a national process for the national forests that was begun with

direction that can be achieved through national NFMA and has been evolving under Forest Service

forest planning and other Forest Service activities. leadership.
Chapter 3

The Goals of National Forest

Management and Planning
Contents

Page

Purpose and organization . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 33

National Forest Goals: Multiple Use and Sustained Yield . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 34

Historical Development . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 34

Philosophical Basis for Government Ownership . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 42

What Is Multiple Use? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 43

What Is Sustained Yield? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 47

National Forest Planning: Achieving the Goals . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 49

Planning Direction and Framework . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .49

Strategic Planning for the National Forests . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 49

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

Boxes

Box Page

3-A. Livestock Grazing, Recreation Use, and Timber Production Trends

in the National Forests . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 36

3-B. Privatization of Federal Lands . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .44

3-C. The National Forest System as a Natural Resource Trust Fund . . . . . . . . . . . . . . . . . . . . . . . . 48

Figures

Figure Page

3-l. Grazing in the National Forests . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 36

3-2. Recreation Use of the National Forests . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 37

3-3. Forest Service Timber Sale Program . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 38

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

. . . . . . .

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

Table

Table Page

3-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 sale

practices were successfully challenged in several

lawsuits (the first and best known being the "Monongahela Decision’ ), on the grounds that the agency

was violating specific provisions of the 1897 Forest

Service Organic Act. The Forest Service argued that

scientific evidence and 70 years of experience

justified their practices, but the court held that only

Congress could change the legal restrictions on

selling timber. In the National Forest Management

Act of 1976 (NFMA), Congress eliminated the

restrictive provisions of the 1897 Organic Act,

provided substantial guidance to the Forest Service

for preparing land and resource management plans

for units of the National Forest System, and required

public participation in determin ing management

direction. It was hoped that an open planning process

could resolve local controversies at the local level,

and get Congress and the courts out of local, detailed

national forest management.

To date, Forest Service planning under NFMA

has not fulfilled this vision. Controversy, litigation,

and congressional involvement abound in management of the national forests. In the South, clearcutting is prohibited near red-cockaded woodpecker

colony sites in the national forests. Administrative

appeals in the northern Rocky Mountains have

delayed enough timber sales to cause a timber

supply squeeze for some sawmills. A Wyoming

sawmill sued to try to guarantee minimum Forest

Service timber supplies under a timber management

plan, but lost and was subsequently closed. Controversy over road construction has led Congress to

consider, and sometimes to enact, substantial changes

in road construction appropriations (292).

The current forest management controversy with

the greatest impact is over the national forests of the

Pacific Northwest—how much timber to sell, and/or

how much ancient forest to reserve from harvesting

for the protection of the northern spotted owl and the

old-growth Douglas-fir ecosystem. As plans for the

national forests in western Washington and Oregon

were being developed (long after the target date

specified in NFMA), courts enjoined timber sales

which might threaten the owl’s existence. Congress

acted to continue the timber sale program while the

U.S. Fish and Wildlife Service considered protecting the owl under the Endangered Species Act. (The

owl was subsequently determined to be threatened,

according to the provisions of that act.) Courts have

since ruled portions of the congressional intervention to be unconstitutional.

Some have characterized these problems as regional battles over the control of resources. In places

where commodity production is being curtailed,

some users, Members of Congress, and agency

employees assert that national forest management is

gridlocked. Congress has been asked to consider

legislation to overhaul the system. Some proposals

would prohibit clearcutting, others would add guidance on forest plan implementation, still others

would prevent judicial review of Forest Service

decisions. Some observers have suggested that many

of the problems result primarily from the belief that

NFMA planning could resolve controversies, and

that repealing NFMA would resolve at least some of

the current difficulties (18). Others go further,

suggesting that the experiment in public land and

resource ownership is a failure, and that radical

reform of the system is the only solution (41).

Nonetheless, many believe that the current planning

process, with improvements, is still appropriate.

PURPOSE AND ORGANIZATIO N

These problems and proposals led Congress to ask

OTA for an assessment of the technological, biological, social, and economic dimensions of the forest

planning process established under NFMA. To

assess these aspects of the NFMA planning process,

one must first examine the purposes of national

forest management: multiple use and sustained

yield, as defined in law. These goals are examined

from their historical development, from their philosophical basis, and from their implications for

management.

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-
—

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

After examining the management goals, this

chapter describes the strategic nature of the NFMA

planning process. Strategic planning is a useful

standard for examining the NFMA planning process

for two reasons. First, although Congress did not

expressly create a strategic planning process for the

national forests, national forest planning is part of

the strategic planning process created in the Forest

and Rangeland Renewable Resources Planning Act

of 1974 (RPA).2 Congress clearly intended the RPA

process to be strategic planning (259), and thus

implicitly intended strategic NFMA planning by

making the land and resource management plans for

the national forests a part of the RPA Program

(section 6(a)).

Second, a public strategic planning process is an

effective approach for identifying organizational

goals for a government agency. NFMA established

an open, public process for setting management

direction for the national forests. Forest plans are to

describe that direction by identifying goals for

conditions and outputs, together with: 1) the standards and guidelines for management activities, 2) the

proposed and possible actions, and 3) the financial

resources necessary to fulfill those goals. Strategic

planning is an appropriate criterion for assessing

national forest land and resource management planning under NFMA.

The subsequent chapters of this report assess

specific aspects of the planning process—legal

context, social dimensions, biological aspects, planning technologies, economic considerations, and

organizational characteristics. The principal criterion for examining these aspects is how they

contribute to strategic national forest planning, both

in theory and in practice. The last chapter concludes

this assessment by reviewing the relationship between strategic NFMA planning and the Forest

Service’s national planning effort under RPA.

NATIONAL FOREST GOALS :

MULTIPLE USE AN D

SUSTAINED YIEL D

Historical Development

Creation of the National Forests

Numerous devastating natural disasters, often in

conjunction with extensive logging, occurred in the

United States during the late 1800s. Huge wildfires

swept through logged-over lands in New England

and in the Lake States in 1871, 1881, and 1891; the

1871 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 1880s

were blamed on widespread deforestation (190).

These events led Congress, in 1891, to grant the

President authority to reserve important public

domain lands, but Congress did not authorize efforts

to protect the reserves.

In 1897, in response to President Grover Cleveland’s substantial forest reservations, Congress indirectly guided management of the forest reserves

(renamed the national forests in 1907) by limiting

the purposes for which the President could reserve

forest lands. Reserves were to exclude lands more

valuable for mineral extraction or for agriculture,

and could only be established:

. . . to improve and protect the forest within the

boundaries, or for the purpose of securing favorable

conditions of water flows, and to furnish a continuous supply of timber for the use and necessities of

citizens of the United States , . .

This was the principal congressional direction for

the purposes of reserving lands and managing

reserved lands, and has come to be known as the

Forest Service Organic Act. The act also authorized

the agency to regulate the “occupancy and use [of

the reserved lands] and to preserve the forests

thereon 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 plans

for units of the Nationat Forest System using an interdisciplinary approach to integrate physical, biological, economic, and other sciences. NFMA added

substantial guidance for public participation and for relevant considerations in the planning process. These land and resource management plans are often

ealted 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 tie

detailed legal requirements of these laws.
Chapter 3-The Goals of National Forest Management and Planning ● 35

The floor debate over this act strongly indicates

that the primary intent was to protect the forests and

the downstream water flows.4 Wood was to be made

available to settlers and to miners who needed the

timber locally, but providing wood for loggers was

not a consideration in establishing forest reserves.

Senator John Lockwood Wilson of Washington

noted:

, . . the timber lands withdrawn [that are more than

25 miles from Puget Sound] do not contain merchantable timber. They have only their value, if any,

for mining purposes (326).

Senator George Laird Shoup of Idaho, in arguing for

permission to sell timber from the reserves, added:

. . . We do want to protect and will protect our timber

if the reserves are only established in the right place.

But, Mr. President, our farmers and our miners are

entitled to a sufficient quantity of timber for domestic purposes (233).

Thus, Congress was clearly concerned about the

local community impacts of reserving Federal forest

lands. In the subsequent century, the national forests

have become an important source of wood for the

lumber and plywood needed in home building and

other uses. Nonetheless, the principal concerns in

establishing the forest reserves were for protecting

the lands and waters while making a continuous

supply of timber available.

Following the transfer of the reserves to the

Department of Agriculture in 1905, the management

activities of the new Forest Service (created when

the Forestry Division of the Department of the

Interior’s General Land Office was merged with the

Department of Agriculture’s Bureau of Forestry)

generally focused on land and resource protection.

The first efforts were to protect the forests from

wildfires and from trespass (illegal timber cutting

and homesteading), and to control grazing, which

had been unregulated by the Department of the

Interior (329). The Forest Service based its efforts on

the broad, general provision in the 1897 Organic Act

permitting the Secretary of Agriculture ‘‘to regulate

their [the forest reserves’] occupancy and use and to

preserve the forests thereon from destruction . . .“

The livestock industry challenged the Forest Service’s right to regulate use and charge fees, but the

agency’s position was upheld by the U.S. Supreme

Court in 1911 (240).

In 1911, Congress also authorized the Forest

Service to acquire lands for the National Forest

System. The Weeks Law authorized land acquisition

to protect water flows; acquiring land to provide

timber was not authorized until the Clarke-McNary

Act of 1924. Many of the national forest lands in the

eastern half of the country were acquired under the

Weeks Law, and, unlike those in the west, many had

been denuded or severely degraded before the

Federal Government acquired them. Thus, in origins

and biological and cultural histories, the eastern

national forests are quite different from the national

forests in the west.

I n summary, the concept of using the national

forests in many ways was implicit from the very

beginning. When use levels were low, conflicts

among users were minor and could be managed by

separating uses. Public discussion of the compatibility of uses did not begin until after the National Park

Service was created in 1916. In the following years,

the Park Service tried, sometimes successfully, to

gain control of prime Federal recreation sites. The

Forest Service countered Park Service efforts by

arguing that proper management of the various land

uses could provide both recreation and commodity

extraction, that ‘‘multiple use’ was preferable to

‘‘single use. ’

The Multiple-Use Sustained-Yield Act of 1960

The debate with the Park Service and disagreements with ranchers continued to simmer until about

1950. Then, during the next decade, several conditions and events led the Forest Service to believe in

the need for legislative sanction to define the

purposes of the national forests and to preserve

Forest Service discretion in managing those lands.

The demand for the goods and services provided

by the national forests began to change after World

War II. Livestock grazing had been the major use of

the reserves when the Forest Service began managing the lands, but livestock use of the national forests

peaked in 1920 and has slowly declined since (298).

In contrast, recreation and timber harvesting began

slowly, then accelerated after World War II. (See

box 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 were

filed on the 1897 act, because it was an amendment to an appropriations bill. This was a common practice at that time, because the appropriations

committees did not exist until the 1920s. Appropriations bills were developed by what are now known as authorizing committees.
36 ● Forest Service Planning: Accommodating Uses, Producing Outputs, and Sustaining Ecosystems

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 1905

from the Department of the Interior to the Forest Service in the Department of Agriculture. Livestock grazing

continued 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 unavailable

to show the magnitude or consistency of the increase.) National forest recreation use was generally below 10 million

visitors annually prior to 1946, but climbed to about 25 million in 1950, and rose to more than 100 million

visitor-days by 1961.1 Recreation use has continued to climb, exceeding 250 million visitor-days in 1989. (See

figure 3-2.) This is not to suggest that all uses have increased equally. Motorized recreation, travel to destination

resorts, 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 uses

toward 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, national

forest timber harvests averaged less than 1 billion board feet (BBF) annually. In 1950,3.5 BBF were harvested, and

this rose annually, reaching 12.1 BBF by 1966. (See figure 3-3.) In contrast to the continued growth in recreation

use, 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 (see

figure 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 technology-greater product output from the same amount of timber input-has also contributed to the increased

lumber and plywood production.

IR=~m ~~m=- ~ visits ptior to 1%5, ~ has beenmessurd invisitordays since 1%5. Howevtx, the c-e k measure

is apparently insignifkant for mportmg “ the treads ill recreation qSs * 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-days

300 –

250 -

200-

150-

100-

5 0–

1

0 r 1 I I r I r

1944 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 opportunities

and values. The simultaneous increase in the Forest

Service timber program and in national forest

recreation use in the 1950s and early 1960s probably

magnified the conflicts over national forest management.

Ranchers tried to increase their influence in determining livestock permit numbers, fees, and other

matters, and convinced Senator Frank Barrett of

Wyoming to introduce a bill to this effect in 1953

(329). In the same Congress, the timber industry

pushed for industry selection of public timberland as

compensation for private timberland flooded by

Federal dam projects (329). Although these efforts

were unsuccessful, they indicated an interest in

partitioning the national forests among interest

groups.

Another effort to reduce Forest Service discretion

began in 1955: the first bill to establish a wilderness

system was introduced. The Forest Service was

surprised by the bill, because it had administratively

established a system of wilderness, wild, and primitive areas in the National Forest System, beginning

in 1924. However, administrative boundary modifications and pressures to expand national forest

timber harvests led some to believe that statutory

protection was necessary to preserve undeveloped

areas in the national forests. (See the following

section on the Wilderness Act.)

Then, in 1956, the Park Service launched Mission

’66 to increase the size of the National Park System

substantially. This was seen as a threat to the

national forests, since many parks had been created

from national forest lands. Furthermore, President

Dwight D. Eisenhower supported Mission ’66, but

the Forest Service was unable to obtain financial

support for its countermeasure, Operation Outdoors.

Taken together, these events and conditions led

the Forest Service to believe in the need for

legislative blessing of their existing management

direction. The multiple-use legislation proposed by

the Forest Service won only lukewarm support. Few

outside the agency believed it was necessary,

although several conservation groups endorsed it.
—

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

Figure 3-3-Forest Service Timber Sale Program

14

12

10

8

6

4

2

Billion board feet

w I ‘- Timber sold I

1

+ Timber cut

o

1

I 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 timber

industry initially opposed new legislation, believing

the Forest Service Organic Act gave timber production more prominence than the multiple-use bill. The

industry offered a substitute directing stronger

financial considerations in national forest management. Other potential opponents, such as the Sierra

Club and The Wilderness Society, generally stayed

clear of the debate, focusing their attentions on

statutory wilderness protection. Thus, after a relatively brief and mild struggle, the Forest Service was

rewarded with the Multiple-Use Sustained-Yield

Act of 1%0 (MUSYA), stating that:

. . . the national forests are established and shall be

administered for outdoor recreation, range, timber,

watershed, and wildlife and fish purposes. The

purposes of this Act are declared to be supplemental

to, but not in derogation of, the purposes for which

the national forests were established as set forth in

the Act of June 4, 1897 . . .

. . . The establishment and maintenance of areas of

wilderness are consistent with the purposes and

provisions of this Act.

In enacting MUSYA, Congress essentially sanctioned Forest Service management to provide a

broad array of natural resource uses and outputs,

while protecting the land and resource base of those

uses and outputs. Congress accepted the agency’s

legislative proposal, because the proposal did not

change national forest management direction or

congressional oversight or authority. MUSYA expanded upon the national forest purposes set forth in

the Organic Act and together they provide broad

direction and substantial agency discretion for

managing the National Forest System.

The Wilderness Act

The Forest Service had long recognized the value

of keeping some lands undeveloped. In 1924, under

its general adminis. trative authority, the agency set

aside the Gila Wilderness in New Mexico, and

subsequently established a system of wilderness,

wild, and primitive areas. However, some observers

were concerned about the administrative authority to

modify area boundaries and about increasing pressures to expand national forest timber harvests, and

proposed statutory protection for specific undeveloped 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

0

195 0 195 6 196 2 196 8 1974 198 0 198 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 of

northern Minnesota illustrate the concerns. After

World War H, the Forest Service proposed several

large, long-term timber sales in the area, over

long-standing local opposition. This led local conservationists —and eventually Senator Hubert

Humphrey of Minnesota-to believe that timber

from all national forest lands would be harvested,

except where harvesting was prohibited by law

(329). Comparable situations elsewhere led conservation groups, which had supported the Forest

Service against the ranchers and loggers, to support

the idea of statutory wilderness protection.

The Forest Service included a provision in the

Multiple-Use Sustained-Yield Act of 1960, noting

that ‘‘the establishment and maintenance of areas of

wilderness are consistent with the purposes and

provisions of this Act. However, wilderness proponents were still not satisfied, and the Wilderness Act

creating the National Wilderness Preservation System was enacted in 1964.

The Wilderness Act provides more explicit guidance for managing the designated areas than the

Organic Act and MUSYA do for the other National

Forest System lands. The Wilderness Act generally

prohibits commercial activities and road and facility

construction in the designated areas. Compatible

commercial activities (e.g., outfitter services) were

exempted, and grazing and other nonconforming

uses (especially motorized access) were generally

allowed to continue, if those uses had been established before the area was designated as wilderness.

Furthermore, valid existing mineral rights were

protected, and the act permitted new rights to be

established for about 20 years (specifically, until

Dec. 31, 1983). In essence, the Wilderness Act

prohibited timber harvesting, new recreation facilities, and new motorized access in the areas designated as wilderness by Congress.

The Forest and Rangeland Renewable

Resources Planning Act of 1974

RPA was enacted because of concerns about

short-sighted, political decisions for the Nation’s

renewable resources. At that time, public trust in

government was deteriorating-the Watergate scandal was breaking and Vietnam War protests were
40 ● Forest Service Planning: Accommodating Uses, Producing Outputs, and Sustaining Ecosystems

expanding. Congress was reasserting control over

the Executive Branch—for example, the Congressional Budget and Impoundment Control Act (which

preceded RPA by a month) reestablished congressional control of the budget, following impoundments (nonspending of appropriations) by the Nixon

Administration. Senator Hubert Humphrey, the principal sponsor of RPA, asserted that the administration’s short-term spending priorities were shortchanging renewable resource management.

RPA established an open, strategic planning

process by which the Forest Service would address

the long-range renewable resource situation in four

documents. First, an Assessment produced every 10

years would examine resource conditions, trends in

supply and demand, and opportunities to invest in

resource production. Then, every 5 years, a program

would establish the direction for all Forest Service

activities, to respond to the trends and opportunities

identified in the Assessment. The Program was to be

consistent with the principles set forth in MUSYA

and in the National Environmental Policy Act of

1969 (NEPA). Thus, Forest Service activities under

the RPA Program are to provide for multiple uses

and sustained yields, and the Forest Service is to

include users and other interested parties in setting

national direction for Forest Service activities. A

Presidential Statement of Policy, which accompanies each Program, would then be used to guide the

annual budget requests. Finally, an Annual Report

would assess Forest Service accomplishments and

progress in implementing the program.

RPA also required the Forest Service to prepare

“land and resource management plans for units of

the National Forest System. These plans were to be

coordinated with other Federal, State, and local

planning processes, and were to be developed using

‘‘a systematic interdisciplinary approach to achieve

integrated consideration of physical, biological,

economic, and other sciences. ’ The plans were

considered part of the RPA Program, and thus were

to be consistent with MUSYA and NEPA. Thus,

RPA confirmed MUSYA as the management principle for the national forests, and essentially established the requirement for public participation in

national forest planning.

The National Forest Management Act of 1976

NFMA was enacted primarily in response to

several lawsuits. The initial suits successfully argued that clearcutting in the Monongahela National

Forest violated the Forest Service timber sale

authority in the 1897 Organic Act. The lower court

decision was upheld by the 4th Circuit Court of

Appeals in August 1975. Then, in December, the

Federal District Court of Alaska extended this

decision to the long-term timber sale contracts in

Alaska. 6 In July 1976, a preliminary injunction

followed the same logic to halt clearcutting in the

National Forests in Texas.7 Several other lawsuits

were filed in late 1975 and in 1976 to stop

clearcutting in the national forests. The timber

industry and the Forest Service argued that clearcutting was a sound timber management tool, and that

a ban would devastate the timber economy. If all the

litigation were successful, Forest Service timber

sales would probably have fallen by half (261).

However, in the Monongahela case, the Court of

Appeals stated that it could only apply the existing

law; if the law was an anachronism, it was up to

Congress, not the courts, to remedy the situation.

The lawsuits challenging clearcutting were only

one expression of growing public dissatisfaction

with national forest management. The 1970 Belle

Report (264) described problems on the Bitterroot

National Forest in western Montana. The Senate

Committee on Interior and Insular Affairs held

extensive hearings on clearcutting around the country in 1971, and issued recommendations for Forest

Service clearcutting in a committee report, commonly known as the Church Clearcutting Guidelines

(265). In 1970, the Forest Service had on its own

initiative begun a review of the wilderness potential

of many national forest roadless areas (RARE I), but

this review was halted in 1972 because of litigation

charging the Forest Service had been arbitrary in

selecting the areas to be reviewed (294). Forest

Service management was, in essence, being challenged in many ways and places.

Bills were introduced to make a simple, technical

correction to the Organic Act, making it legal to

clearcut 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, rather

than just address the immediate problem. Upon

introducing NFMA, Senator Hubert Humphrey of

Minnesota stated that:

Time has demonstrated that we need more than a

new prescription for selling timber. We need a

fundamental reform in managing all of the resources

associated with forested land of the national forest

system . . .

To me it is not enough that we modernize the

methods by which timber is sold. This bill does much

more. Its basic purpose is to assure that the multiple

uses are realized and their yields are sustained. This

bill seeks to strengthen resource management so that

it is ecologically effective (120).

Because RPA required land and resource management plans for units of the National Forest System,

Congress chose to guide the local planning process

by amending RPA. This option also fit with Congress’ intent to retain the basic direction for the

National Forest System, as set forth in the Organic

Act and MUSYA. NFMA was intended to assure

balanced use and protection of all the resources,

today and tomorrow. As noted in the Senate

Committee Report:

The role of the Forest Service in the management

of the National Forest System is to act as a steward

of the land . . .

Timber production and sale are important aspects

of the overall management of the National Forest

System lands, However, they are not the sole

objectives of management planning . . .

The other resources of the forests, wildlife and fish

habitats, water, air, esthetics, wilderness must be

protected and improved. Consideration of these resources is an integral part of the planning process. . .

It is, therefore, time for Congress to act in order to

insure that the resources found in our National

Forests can be used and enjoyed by the American

public, now and in the future (261).

Senator Humphrey described the relationship among

NFMA, RPA, and MUSYA by noting that “The

Forest and Rangeland Renewable Resources Planning Act and these amendments are intended to be

fully compatible with the principles of the MultipleUse Sustained-Yield Act, and, in fact, to provide

further direction in the implementation of that act”

(120).

Much of NFMA is an amendment to the land and

resource planning requirement of RPA. Some amendments provide considerations for management. For

example, section 6(k) specifies consideration of

physical, economic, and other pertinent factors in

determining the suitability of land for timber production. NFMA also establishes standards and

guidelines for planning. For example, section 6(f)(2)

requires the plan to reflect proposed and possible

actions, including the planned timber sale program,

and section 6(g)(2)(A) directs the Forest Service to

identify lands suitable for resource management.

Section 6(g)(3) directs guidelines to achieve the

goals of the RPA Program, while subsection (A)

specifies the consideration of the economic and

environmental aspects of resource management

systems, and subsection (F)(ii) requires an assessment of potential environmental, biological, esthetic, engineering, and economic impacts of each

timber sale. In addition, section 6(1) requires estimates of long-term benefits and costs and a representative sample of government returns and expenditures associated with the sale of timber.

NFMA also establishes standards and guidelines

for assuring protection of the resources of the

national forests. Examples include providing for a

diversity of plant and animal communities (section

6(g)(3)(B)); prohibiting irreversible soil, slope, and

watershed damage (section 6(g)(3)(E)(i)); assuring

adequate reforestation within 5 years (section 6(g)

(a)); protecting waters, wetlands, and riparian

areas (section 6(g)(3) (E)(iii)); limiting the size of

clearcuts (section 6(g)(3) (F)(iv)); revegetating roads

unless the need for a permanent road is specified in

a road plan (section IO(b)); and generally limiting

timber sales to a quantity that can be harvested

annually in perpetuity on a sustained-yield basis

(section 13(a)). Thus, NFMA requires many considerations, standards, and guidelines in planning for

the management of the national forests under

MUSYA.

While the Organic Act and MUSYA define the

parameters of management, and NFMA details

considerations, standards, and guidelines, NFMA is

not a set of prescriptions for national forest management. RPA and NFMA establish a planning process

that leaves substantial management discretion with

the agency. Furthermore, NFMA clearly intended

that management, as set forth in the forest plans,

respond to the desires and concerns of the people, as

expressed locally and through the national strategic

planning process under RPA. NFMA explicitly

requires “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 conducted

in accordance with NEPA, and NEPA also requires

that Federal agencies consider public input in

decisionmaking.

In sum, NFMA emerged in response to lawsuits

that would have substantially reduced Forest Service

timber sales. However, Congress chose to provide

guidance for the required forest management plans,

rather than enact only management prescriptions or

a technical correction to the timber sale authority.

The guidance is mostly in the form of planning

considerations and standards and guidelines for

analyzing, reporting, and protecting the quality of

resources and the environment. NFMA was also

intended to assist in producing the high-level of

sustainable outputs required under MUSYA. NFMA

leaves the Forest Service with substantial Forest

Service discretion in managing the national forests,

but requires the agency to consider public interests

and concerns, and directs that the forest plans be

prepared in accordance with NEPA. Thus, the

Organic Act and MUSYA provide a framework for

managing the national forests, while NFMA and

NEPA essentially direct that local resource conditions and public desires and concerns be considered

in determining the details,

Philosophical Basis for

Government Ownership

There are two, interrelated reasons for government ownership and management of forests and

rangelands and of renewable resources: 1) the

production of one resource output can affect other

resources, and 2) many resource uses are not

currently marketed. Forests and rangelands clearly

produce more than just one output or value; a forest,

for example, can simultaneously grow timber, provide food and cover for wildlife and livestock, and

yield water for human use, land animals, and fish.

Activities to modify one aspect of the forest will

affect other uses and values. For example, thinning

a timber stand to increase timber growth might also

increase water yields and forage production, but

might decrease wildlife cover and water quality.

This interrelationship among outputs is generally

known as joint production.

Joint production can be a problem for natural

resource management, because many resource values are not marketed. (See box 3-B.) Timber is the

only national forest output priced in a competitive

market, 8 and even for timber, the Forest Serv ice does

not respond to market signals in traditional ways

(increasing sales when prices and/or profits rise, and

decreasing sales when prices and/or profits fall). For

other national forest resources, markets are not used

to set prices or to signal appropriate operations and

investments.

While markets can improve production efficiency, efficiency was explicitly rejected as the

guiding principle for managing the national forests.

In debating MUSYA, the House Committee on

Agriculture did not even consider a timber industry

proposal to base management direction on financial

considerations (329); instead, MUSYA directed that

management need not be ‘‘the combination of uses

that will give the greatest dollar return or the greatest

unit output. ’ Implicitly, Congress recognized the

limitations of markets in providing a balanced mix

of resource values, and accepted the Forest Service

bill making multiple use and sustained yield the

appropriate directions for national forest management.

Congress maintained this philosophy in enacting

NFMA. As a result of the Belle Report (264) and

other evidence of uneconomical timber investments,

the Senate included a financial standard (production

costs less than economic returns) for lands with

timber production as a management goal. A similar

provision was considered and rejected by the House

Committee on Agriculture and on the floor of the

House. The substitute, agreed upon by the conference committee and accepted by both Houses,

requires consideration of economic (and other)

factors in determining lands not suited for timber

production, and then allows timber salvage sales and

sales to protect multiple-use values on lands not

suited for timber production. Section 6(l)(1) of

NFMA also requires the Forest Service:

. . . to provide information on a representative

sample basis of estimated expenditures associated

with reforestation, timber stand improvement, and

sale of timber from the National Forest System, and

shall 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 SaleS

in 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 sale

of timber . . .

However, NFMA does not proscribe agency

actions or require responses based on the comparison of costs and revenues.

What Is Multiple Use?

MUSYA defines multiple use as:

. . the management of all the various renewable

surface resources of the national forests so that they

are utilized in the combination that will best meet the

needs of the American people; making the most

judicious use of the land for some or all of these

resources or related services over areas large enough

to provide sufficient latitude for periodic adjustments in use to conform to changing needs and

conditions; that some land will be used for less than

all of the resources; and harmonious and coordinated

management of the various resources, each with the

other, without impairment of the productivity of the

land, with consideration being given to the relative

values of the various resources, and not necessarily

the combination of uses that will give the greatest

dollar return or the greatest unit output.

This definition of multiple use is not very useful

for determining the proper management of the

national forests. The only goal is to meet the needs

of the people, while the only limitation is to protect

the productivity of the land. In addition, multipleuse management is to consider relative resource

values, but maximizing returns or outputs is not to be

the sole basis for determining management. (This

last provision was apparently a response to the

timber industry’s proposal for the multiple-use bill

to emphasize financial considerations in Forest

Service management decisions.)

Joint Production or a

Dominant-Use Patchwork?

The concept of multiple use encompasses two

distinct views about managing to produce outputs

and uses: joint production and patchwork of dominant uses. As noted above, joint production recognizes that forests and rangelands are ecosystems that

can produce more than just one use or output of

value-they provide wildlife habitat, yield water,

can be used for recreation, and produce timber and

forage for livestock.9 Management of one use or

value will affect the others; for example, a clearcut

yields timber, generally increases water flows,

augments forage for livestock and wildlife, and

provides access to new areas for some types of

recreation, but may also degrade water quality and

eliminate wildlife cover and certain recreation opportunities, at least temporarily.

While joint production is clearly an accurate view

of the ecological interactions on forests and rangelands, it is difficult to apply the concept to land

management. Despite the long-standing recognition

of joint production, our understanding of the relationships among resource values is incomplete. The

biological and social sciences have, to date, provided only a fragmentary picture of the ecological

interactions for a given site. Furthermore, seemingly

minor variations in activities or locations can cause

substantially different interactions among resources

depending on soil types, the nature and condition of

surrounding sites, and other factors. Finally, no

objective way exists to determine whether the net

result of management actions on all of the current

and future uses and outputs is desirable. Economics

(usually benefit-cost analysis) is often used to

evaluate the results, but the limits of economic

analysis combined with the limits of our knowledge

of biological and social interactions make such an

evaluation incomplete, at best. (See ch. 8.)

Another view of multiple-use management, a

patchwork of dominant uses, provides clearer direction for land managers. Under this approach, lands

are divided into management units, and each unit is

managed to produce more (or higher quality) of the

dominant use(s) or output(s) while maintaining

environmental and resource quality standards. Despite the visceral reaction of many to the concept of

dominant-use management, this approach to achieving multiple use is clearly consistent with MUSYA.

The phrases “judicious use of the land for some or

all of these resources’ and ‘‘some land will be used

for less than all of the resources” suggest that the

Forest Service (which drafted the definition) believed that multiple use could be achieved by

separating conflicts in space. Furthermore, some

uses must be separated, because they are incom91t should be noted tha~ in different situations, multiple use may mean something other than the broad variety of uses and outputs commonly

associated with forests and rangelands. In the mineral industries, for example, multiple use means allowing more than one type of mineral extraction

from 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).
44 ● Forest Service Planning: Accommodating Uses, Producing Outputs, and Sustaining Ecosystems

Box 3-B—Privatization of Federal Lands

Since the late 1970s, some have questioned the validity of the historic justification for Federal land and

resource ownership. Classical economics, dating back to a century before Adam Smith, asserts that governments

should minimize their interference with private land allocation and production decisions, because government

interference necessarily reduces optimal output (21 1). Citing this theoretical base, “sagebrush rebels” and others

have argued for privatization--the disposal of the national forests (and other Federal lands) by selling or transferring

the land to individuals and organizations in the private sector (45, 180). This approach would end or at least limit

Federal land ownership, and rely principally on private market responses to consumer demands for determining

resource use and protection. A less draconian form of market responsiveness, called marketization, would retain

Federal ownership, but seek to reap the benefits of private markets by rewarding Forest Service managers for

responding to consumer demands (187). This would require establishing markets for many uses and outputs that

are not currently marketed or that are subsidized.

Benefits of Market-Based Decisions

Markets 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 to

balance 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 when

demand 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 lead

to efficient production among the marketed resources. Prices and production costs determine the most profitable

operations and investments. Assuming that managers respond to profits, actions will be shifted to producing the

most profitable goods and services-those with high prices (strong demand) relative to the cost of production. These

shifts 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 among

all the marketed resources.

Limitations of Market-Based Decisions

The 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, some

recent clearcut, for example. Thus, a dominant-use

patchwork is, in some cases, necessary.

Applying a dominant-use patchwork for managing the national forests is not without difficulties.

Our incomplete knowledge of ecological and social

interactions also restricts multiple-use management

under this view, although less detailed understanding is needed for setting environmental and resource

quality standards and for monitoring results to

assure that standards are met. However, determining

standards is not a technical process. It is a social

process, with the affected and interested individuals

and groups defining the minimum acceptable standards. Defining the patches--which lands are managed for which uses—is also not a purely technical

process. Most lands can be managed for various

uses, emphasizing timber production, water produclands that are highly effective at producing one value

(e.g., timber) might also be highly effective at

producing another (e.g., wildlife), and joint management of the values might produce more of both than

would be produced in a dominant-use patchwork.

The ability of sites to produce conflicting values—

e.g., wood and undisturbed ecosystems—is the heart

of the controversy over preserving old-growth

Douglas-fir forests in western Washington and

Oregon. Thus, although technical production is an

important consideration in determiningg the dominant use for a patch of forest or rangeland, the

demands and desires of the affected and interested

individuals and groups must also be considered.

In reality, multiple-use management is more

complicated than either joint production or a dominantuse patchwork suggests, and ‘multiple-use manage-
Chapter 3—The Goals of National Forest Management and Planning ● 45

value of grazing(181, 281). Often, uses are subsidized to ensure availability to all, particularly for recreation. Market

proponents argue that subsidies will lead to overuse, and that price can be used to efficiently allocate the supplies

among potential consumers. However, price uses wealth and income for allocating use, while other allocation

mechanisms, 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 to

enforce market transactions is quite high; for example, the current easy access to national forests makes it difficult

to ensure payment of the fair market value for dispersed recreation. Furthermore, the numerous highways and

inholdings bring in many visitors whose primary purpose is not visiting the national forest. A similar difficulty is

being able to relate increased outputs to management activities. For example, increased water flow may result from

managerial efforts, but it also may simply result from additional precipitation; such uncertainty (together with

existing 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 guiding

management of the national forests.

In addition, the collective-goods nature of some resources may prevent the creation of markets (31). Collective

goods are provided for everybody, if they are provided at all, because people cannot be excluded from receiving

the 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 than

from using them. This is not to say that everybody wants the collective good; some people undoubtedly get little

personal benefit from knowing spotted owls exist. However, markets work because each buyer can choose the

amount of the specific goods or services bought, whereas the collective nature of nonuse values prevents each

American 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. Markets

involve transactions between buyers and sellers, but occasionally transactions harm people who are not involved

in the transaction. For example, when a landowner sells timber, the buyer and the seller are involved in the

transaction, but others--recreationists, sightseers, downstream water users, etc.—may be affected by the timber

sale. If all resource uses and outputs were sold in equally efficient markets, the externalities would be resolved

within the marketplace. However, the high transactions costs for some resources and the collective-goods nature

of other resources prevent establishing equally efficient markets for all resources. Therefore, externalities would

plague 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-use

combination of the two. Early Forest ‘Service management apparently focused on the dominant-use

patchwork approach—use levels were relatively

low, and conflicts were managed simply by separating users. As timber harvesting and recreation use

increased after World War II, managing the conflicts

became increasingly important and increasingly

difficult. While the Forest Service still manages

some conflicts by separating users in space and time,

it also attempts to accommodate other values by

modifying dominant-use management. Such modifications to dominant use may reflect the jointproduction nature of forest and rangeland outputs

and values, but they are only assumed to approximate joint production.

In practice, joint production and dominant-use

patchwork can lead to quite different management

management, therefore, provides little guidance

for land management, and can be very misleading

when used to describe management direction. As

recently as 1989, Henry Vaux noted the lack of

agreement on the meaning of multiple use:

Why such an apparent conflict in meanings?

Because the symbol [multiple use] has at least some

validity in describing these disparate forms of forest

management . . .

Even in an economic context, multiple use maybe

interpreted in more than one way.

Thus, ‘‘multiple use’ has multiple interpretations, meaning different things to different people.

To some, multiple use necessarily includes use of

commodity resources (timber, livestock forage,

minerals). Areas where such uses are proscribed,

such as recreation sites and wilderness areas, there-
46 ● Forest Service Planning: Accommodating Uses, Producing Outputs, and Sustaining Ecosystems

fore are not considered multiple-use areas. However,

others have noted that such areas still yield water and

are used for recreation and by wildlife (99), while

clearcuts effectively eliminate recreation use of the

harvest site, at least temporarily. It is unclear which

uses or how many uses are necessary for an area to

be managed under multiple use.

Thus, although multiple use assures consideration

of the various resource values and suggests that a

balance among the values is appropriate, its multiple

meanings and various interpretations, together with

the technical difficulties of estimating joint production relationships, limit its usefulness for explaining

or defending alternative management practices.

Confusion in the Act

One source of confusion in practicing multipleuse management is the list of purposes for administering the national forests under MUSYA—

‘‘outdoor recreation, range, timber, watershed, and

wildlife and fish purposes. This list combines uses,

outputs, resources, and land classes as the purposes

for administering the national forests. (See table

3-l.)

This combination of purposes was not accidental.

The terms were selected to assure a particular order

in an alphabetical (and therefore neutral) listing (56,

329). Recreation had to come first, to combat Park

Service efforts to obtain national forest lands and to

show that commodity production was not the first

and foremost purpose of national forest management. Then, a land classification-range-was used

instead of livestock g-razing or forage, to assure that

this commodity use was not listed frost. Timber was

selected to achieve centrality (and implicitly neutrality), although forestry has been (and sometimes still

is) used to describe timber production (53), and

wood products are the end use; however, forestry or

wood products would have meant listing this purpose first (emphasizing it) or last (denigrating it),

neither of which was desired. Watershed was

chosen, both to include soil resources implicitly and

because other Federal agencies (e.g., the Bureau of

Reclamation and the Army Corps of Engineers) are

responsible for providing water. Finally, wildlife

and fish-rather than the more natural phrase, fish

and wildlife, or the more comprehensive term,

animals-was used to assure last place in the listing,

because States have primary jurisdiction over animal management and because the U.S. Fish and

Wildlife Service shares Federal responsibility for

animal management. Thus, although the listing of

purposes used in MUSYA was a hodgepodge of

uses, outputs, resources, and lands, it was politically

expedient.

The odd mixture of uses, outputs, resources, and

land classes in MUSYA has contributed to the

confusion over what multiple-use management is.

Multiple use suggests an emphasis on uses, or

perhaps on outputs. However, the definition focuses

on managing resources and protecting the productivity of the land, and specifically prohibits selecting

the combination of uses that would maximize

returns or outputs. A focus on managing resources

suggests a more integrated, ecological approach to

management than would result from a focus on

producing uses and outputs (17). MUSYA does not

clearly define the proper focus for Forest Service

efforts, and the resulting management thus mixes

resource protection with use and output production

without defining the balance among resource values.

Table 3-l—Uses, Outputs, and Resources Corresponding to the Purposes Listed in

the 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 acceptable

land

Range . . . . . . . . . . . . . . . . . . . . . . Animal products Forage Forage-producing plants and

grazable land

Timber. . . . . . . . . . . . . . . . . . . . . . Wood products Timber Trees and harvestable land

Watershed . . . . . . . . . . . . . . . . . . Water, hydro power Water Precipitation, soil, and protective

vegetation

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

(i.e., recreation) requirements (food, cover, etc.)

SOURCE: Office of Technology Assessment, 1991.
— ———.

Chapter 3—The Goals of National Forest Management and Planning . 47

What Is Sustained Yield?

MUSYA defines sustained yield as:

. . . the achievement and maintenance in perpetuity

of a high-level annual or regular periodic output of

the various renewable resources of the national

forests without impairment of the productivity of the

land.

This definition is much more useful than the

definition of multiple use for determining national

forest 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 protecting and enhancing the fired’s assets. This definition

is also consistent with the original management

direction for the national forests enacted in the 1897

Organic Act-that the lands are protected, that water

flows are secure, and that timber supplies are

continuous.

Historically, sustained yield has been applied

mostly to timber. Providing a sustained timber

supply was a European forestry tradition imported to

America at the turn of the century (188). In

particular, Gifford Pinchot wanted to show that

timberlands could be managed profitably for continuous production, demonstrating that the cut-and-run

practices of the timber industry were unnecessary

(188, 327). Congress has, at various times, given

direction to provide continuous timber supplies-in

the 1897 Organic Act for the forest reserves, in the

1937 0 & C Act10 for managing certain Federal

timberlands in western Oregon, and in the 1944

Sustained Yield Actll authorizing special units of

Federal timberland to be managed to provide timber

for specific local communities.

Sustained yield has also been applied to managing

rangelands and fisheries. The Wilderness Act implies sustainability for natural processes in describing wilderness as “an enduring resource” and in

prohibiting most developments. Nonetheless, MUSYA

appears to be the first time that sustained yield was

broadly applied to all renewable resource values,

and this was probably done in part to counter Park

Service efforts to become the premier Federal

recreation agency. Regardless of why it was proposed, the concept of sustained yield of all resources

may have been the most persuasive reason for

congressional support for MUSYA (56).

There are three limitations to implementing sustained-yield management in the national forests: 1)

the physical/biological bias of the approach, 2) the

limits of knowledge, and 3) the resource focus. First,

sustained yields are determined by the physical and

biological productivity of the sites, with little or no

regard for the relative value of those yields. Essentially, this view assumes that producing more must

be better, regardless of the costs and the impacts on

other values. Bowes and Krutilla(31) noted that the

Forest Service has an ‘‘institutional focus on the

stability of harvest levels and on biological criteria

for timber treatments . . .“ NFMA perpetuates this

view in section 6(m) by identifying the “culmination of mean annual increment’—the age of maximum average physical production-as the standard

for harvesting timber. Thus, sustained yield focuses

on perpetuating supplies by restricting uses and

outputs to growth or carrying capacity.

Furthermore, as discussed above, the biological

and social sciences have provided an incomplete

picture of the relationship between outputs (yields)

and the resource base. Current resource outputs can

be used to estimate productivity, but current productivity is an imperfect predictor of permanently

sustainable production levels. For example, current

timber growth rates can be estimated and used to

determine appropriate harvest levels, but timber

harvests probably alter growth rates by changing

hydrologic patterns and soil nutrients and microfauna. Furthermore, using one resource affects the

current and future productivity of other resources.

Timber harvests, for example, can alter (increasing

or decreasing) both short-term and long-term water

yields, forage production, and animal populations.

The limits of knowledge about ecological and social

relationships make it difficult, if not impossible, to

guarantee the sustained yield of all the resources at

this time.

Finally, the supply and production emphasis

necessarily focuses on the uses and outputs of

individual resources (17). This focus has two effects.

First, it inhibits ecosystem management. Managers

tend 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).

IlsmtiYield F~re~t -=ent ~~ At of ~. 29, 1944, ch. 146 (58 stat. 132; 16 U.S.C 583).
48 ● Forest Service Planning: Accommodating Uses, Producing Outputs, and Sustaining Ecosystems

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 the

large-scale clearcutting that allegedly caused downstream flooding and destructive wildfires. The term reserve has

a 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 term

reserve to convey both meanings: saving the land from timber cutting to preserve water quality and establishing the

capital 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 forest

reserves. The Multiple-Use Sustained-Yield Act of 1960 requires the Forest Service to maintain the productivity

of the land Such direction indicates Congress' desire that the productivity of the national forests be protected, much

as 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 western

national forests, with their substantial reserves of timber and expanses of lands, the eastern national forests were

acquired largely from cut-over lands, without enormous capital assets to be reserved Subsequent management of

these lands has enhanced the asset value of the eastern national forests, and illustrates the possibilities for

management to improve the asset base. Thus, the history of the eastern national forests can also be seen as a Forest

Service success in natural resource trust management.

Managing a trust fund illustrates the dilemma posed for managing the national forests. A trust fund is to

generate 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. In

both cases, managers are responsible for maintaining and enhancing the assets. Annual benefits are important, but

preserving the productive assets is paramount.

In both the National Forest System and trust funds, moreover, professional managers are responsible for

protecting the assets and producing the annuities and must also be responsive to the needs of the beneficiaries. At

times, the beneficiaries may choose to forgo some annuities, to increase future annuities or for some moral or ethical

reason. 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 responsible

professionals, the beneficiaries may prefer a mix of assets and annuities that is less than optimal, as defined by the

professional.

The “annuities” of the National Forest System include not only uses and outputs, some of which are difficult

to quantify (see box 8-A, p. 145), but also some nonuse values. Many people, for example, cherish various aspects

of relatively undisturbed ecosystems. Furthermore, different balances of uses, outputs, and nonuse values yield

different distributions of benefits. For example, building and/or maintaining campgrounds provides little direct

benefit to the timber industry (although the workers may use the campgrounds) or to backpackers; wilderness may

benefit 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 values

provided from forests and rangelands.

Finally, the Forest Service is required by law, to provide the public with opportunities to participate in the

national forest planning process. Thus, the public both benefits from and influences the management of the National

Forest System. This contrasts with traditional trust funds, where the beneficiaries are relatively isolated from trust

management. Nonetheless, trustees are to be prudent managers of the assets, and for a government agency with

assets and annuities that are difficult to quantify, prudence dictates that the beneficiaries be directly involved in

deciding 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 protection

and use of ecosystems. Under this focus, multiple

use will more likely be a dominant-use patchwork,

rather than joint production, with coordinated management of individual resources rather than truly

integrated resource management.

When MUSYA was enacted, protection was

considered necessary only to ensure that uses and

outputs could be sustained. However, people today

also value naturalness, and many wish to see natural

ecosystems protected. The recognition of such

nonuse values is at least part of the controversy over

national forest management in the Pacific Northwest

and elsewhere.

NATIONAL FOREST PLANNING:

ACHIEVING THE GOALS

Planning Direction and Framework

What, then, are the goals for managing the

national forests and how can they be achieved? The

Organic Act and MUSYA frame the goals effectively. National forest management is to accommodate uses, produce outputs, and sustain ecosystems,

with uses and outputs constrained to sustainable

levels. Furthermore, as stated in MUSYA, management is to provide “the combination that will best

meet the needs of the American people . . .’ Thus,

the proper mix of values is, essentially, determined

by the 1) the physical and biological capabilities of

the lands, and 2) the economic, social, and personal

interests of affected and concerned individuals and

groups.

Planning for the management of the national

forests is the means of achieving those goals.

Planning is done whenever activities are proposed.

The first Forest Service “plans” were simple land

allocation decisions to separate conflicting uses.

More formal planning began after World War I, and

expanded following World War II, especially to

organize and coordinate the expanding timber program. By about 1960, the Forest Service recognized

the need for integrated planning to coordinate the

multiple uses of the various resources. However,

planning efforts were still primarily internal, technical approaches to resolving problems and determining direction.

The first legal requirement for national forest

planning was enacted in RPA. The principal purpose

of RPA was to establish a national strategic planning

process for America’s renewable resources (259).

RPA also directed the Forest Service to prepare

integrated land and resource management plans for

units of the National Forest System. Because these

plans were deemed part of the RPA program, they

were to be developed in accordance with MUSYA

and NEPA.

NFMA substantially amended the RPA direction

for forest planning by adding numerous considerations and requirements to be met in the planning

process. However, NFMA provided no additional

guidance on how to determine the mix of resource

uses, outputs, and protection.

Strategic Planning for the National Forests

Taken together, the Organic Act, MUSYA, NEPA,

RPA, and NFMA provide the framework for managing the national forests. The Organic Act and

MUSYA established the foundation-that the Forest Service is to accommodate uses and produce

outputs while sustaining the ecosystems upon which

the uses and outputs are based—but they did not

identify the mix or balance of uses, outputs, and

protection. Instead, MUSYA implicitly acknowledged that the proper mix is determined by people’s

needs, as expressed through public participation and

through legal requirements, and that the mix can

change over time. NEPA provided a framework for

disclosing intended actions and the possible consequences of those actions to the public. RPA required

integrated land and resource management plans, and

NFMA then established several management considerations and requirements, and specified public

involvement in developing, amending, and revising

management plans.

These laws implicitly direct strategic planning for

the national forests. Forest planning is an open

process to set goals for the conditions of and outputs

from the national forests, to identify standards and

guidelines for activities, and to describe the actions

and funding needed to achieve the goals. The public

is to participate in setting technically and politically

feasible condition and output goals for Forest

Service managers. However, forest plans must also

be consistent with the strategic direction set in RPA

planning.
50 ● Forest Service Planning: Accommodating Uses, Producing Outputs, and Sustaining Ecosystems

Setting Direction

Strategic planning is a process for establishing

management direction for an organization. In business, it defines the concept of the firm, and reflects

the social, economic, and political setting within

which it operates. For a Federal agency, strategic

planning begins with a clear statement of the

agency’s mission, defining what service the agency

provides and who the clients/beneficiaries are. The

Forest Service’s current motto-Caring for the Land

and Serving People—is an overgeneralized direction to accommodate uses and produce outputs while

protecting lands and sustaining ecosystems.

The most widespread problem in strategic planning is vague goals (101). Goals must be specific

enough to provide real direction for managers and

concrete enough to measure success. A broad,

imprecise goal, such as “optimize the balance of

resource values,’ is subject to widely different

interpretations. It gives managers no objective basis

for evaluating the impacts and tradeoffs of their

various options; different managers could conceivably undertake diametrically opposed actions under

such general, unspecific guidance. The concrete

goals in a forest plan would identify the quality,

quantity, cost, and time of the uses, outputs, and

conditions that are feasible and desirable, establishing a clear direction for managing the resources and

ecosystems of the national forest and specific

measures to evaluate performance.

Forest plans generally have not provided such a

description of forest management goals. The size

and complexity of a national forest may make it

virtually impossible to provide a comprehensive,

detailed description of the quality, quantity, cost and

timing of all uses, outputs, and conditions. Rather, a

manageable set of goals could be established by

focusing on key issues and concerns, explaining how

management will affect pivotal sites, produce important outputs, and protect critical lands, resources,

and ecosystems. Furthermore, the forest plan could

describe how management is likely to be different

from what was occurring before the plan was

adopted. The Forest Service has recognized this

point, and the 1981 Advanced Notice of Proposed

Rulemaking (287) proposes incremental (rather than

zero-based) revisions for forest plannin g. Nonetheless, by focusing on issues as well as on management

changes, strategic forest plans can both guide the

agency and inform the public.

The Irrationality of Strategic Planning

Strategic planning is messy and imprecise, rather

than rational and scientific (241). It necessarily

involves considering many feasible directions and

selecting the one that best fits the organization’s

character and clientele. No precise, rational, scientific systems exist for making the selection, no

calculus of inputs and outputs can determine the

right choice. Rather, strategic planning means selecting the mission that will work best for a

particular organization, with its current mix of

employees and customers; for a different organization or at a different time, a different option might be

preferable. Furthermore, because the public is both

the “owner” of government assets and the client of

agency programs, a government agency must consider public and political needs and desires in

strategic planning.

The imprecision of strategic planning contrasts

with early expectations about NFMA planning.

Many, inside and outside the agency, believed that

NFMA planning “would essentially be a scientific

process” (276)-that enough facts and the right

computer model would lead to the “right’ answers

for how to manage the national forests. The Forest

Service has recognized the limitations of a rational,

scientific process for forest planning in its recent

internal critique of NFMA planning (276). However,

even from the outset, some observers have noted that

national forest planning was inherently political, and

that a technical, scientific process could not lead to

acceptable plans (3, 49, 79). Despite these early

warnings, the Forest Service is only now acknowledging that forest planning is dominated by public

concerns and interests.

In forest planning, some form of public agreement—

working consensus, informed consent, etc.—is necessary, 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 that

necessarily favors one group or another. Regardless,

the decisions and the rationale for those decisions

must be explained in plain, nontechnical English.

Decisions are also more likely to be accepted, if the

public and the line managers have been involved in

the process, understand the limits of the resources,

and see that consensus cannot be reached. One

common objection to forest planning is that the

public doesn’t understand how and why decisions

were made (277).
Chapter 3—The Goals of National Forest Management and Planning ● 51

To participate fully and constructively, people

need to know what will be decided in the plan, what

decisions will be postponed, and where and when

those decisions will be made (277). Public involvement in strategic forest planning is necessarily an

ongoing process, throughout the preparation and

implementation of the plans. The planning regulations should specify how plan decisions are to be

treated during implementation, and under what

conditions plans are to be amended.

Furthermore, the discussions among the Forest

Service and the public should focus on the important

issues and desires. Needs and desires may be

expressed as concern over particular sites, interest in

achieving certain output levels, or desire to have

areas or resources protected or preserved. The Forest

Service has recently noted that plans are more

successful if the full range of needs is considered—

emotional and symbolic needs, as well as economic

and community needs and organizational needs

(276). Regardless of how they are expressed the

public’s needs, desires, concerns, issues, and interests must all be addressed in every step of preparing

and implementing strategic forest plans.

The Information Base

Planning for a desired future requires some

understanding of the present, including the peculiarities of an organization-its structure, its personnel,

its customers, and its owners or board of directors,

Strategic forest planning would take stock of the

national forest lands and resources, the Forest

Service workforce, the interested publics, and the

American people and Congress.

Inadequate information is a common problem in

strategic planning (101). Complete data will not

‘‘solve’ forest planning problems, because strategic

planning is not scientific, with data and computers to

get the “right’ answers. In addition, measures for

some outputs and conditions will always be imprecise. Nonetheless, strategic planning depends on an

analysis of the current situation-the resource conditions and trends and the public’s concerns and

desires. Knowing the starting point is essential to

determining the actions necessary to achieve the

goals. An inadequate ‘‘situation audit’ would restrict the value of the forest plan as a guide to present

and future Forest Service actions, because the

starting point is uncertain.

The incomplete data on ecosystem conditions,

especially the lack of information on resource

quality, in the RPA Assessment has been noted

elsewhere (259), Data inadequacies in national

forest planning are described in ch. 6 of this report.

Data must not only be complete, they must also be

timely. Outdated resource information in NFMA

planning has been described as a serious problem

(1), and Congress has provided temporary protection

from judicial review to forest management decisions

based on outdated information (28). Furthermore,

sometimes even the issues being considered in forest

planning are out of date, and no longer reflect the

current concerns (1). The outdated information on

resources and concerns principally results from the

long timeframe required to develop the first round of

forest plans, and might not be a continuing problem

if the plans can be revised more expeditiously.

Nonetheless, the timeliness of information, as well

as its completeness and accuracy, must be addressed

explicitly in the planning process.

The assessment of the current situation is a

necessary precursor to examining options and opportunities in forest planning. Inventories must

respond to the issues and concerns for each forest, to

assure that relevant data are collected, and that time

and money are not spent gathering unnecessary

information. The Forest Service has not been consistently successful in identifying relevant data

needs early in the planning process; for example,

although the northern spotted owl was identified as

an indicator species for old-growth Douglas-fir

habitats in the early 1980s, the inventory of spotted

owls and their habitat was not begun until 1989. In

addition, although relevant data are determined by

local concerns and issues, collection methods and

measurements for information that is needed commonly or nationally should be standardized, to allow

for aggregation of data from numerous forests.

Examining options and opportunities is a major

part of the NFMA planning process. The process is

often highly technical, as when land and resource

capabilities are determined, tradeoffs are analyzed,

and management prescriptions are developed. However, the public is affected by and interested in the

results of the analyses, and the users, not technical

standards, determine the compatibility or incompatibility among various uses and outputs of a given site

or adjoining areas. Similarly, while the efficiency of

management prescriptions can be technically evaluated, the prescriptions must be acceptable to the
52 ● Forest Service Planning: Accommodating Uses, Producing Outputs, and Sustaining Ecosystems

public. Thus, examining options and opportunities is

both a technical and a social process.

Implementation

The strategic plan guides an organization’s actions. Although a strategic plan must be implemented, it is neither a long-term budget plan nor an

ironclad commitment (241). This is particularly true

for government agencies, since managers do not

control all the variables that determine implementation (particularly budgets). Instead, the strategic

plan identifies goals for the action plans used to

build annual budgets and to determine activities.

Forest plans should define condition and output

targets for the national forests, which can then be the

basis for budget proposals and for subsequent

actions. They cannot be guaranteed commitments,

because Congress enacts Forest Service appropriations annually. This contrasts with the view of forest

plans as social contracts. Nonetheless, forest plans

are agreements between the agency and the public

about the goals of national forest management, and

should therefore guide budgets and subsequent

actions.

It is unclear whether forest plans are guiding

budget proposals and management activities. Implementation difficulties arise from the complexity of

environmental laws (206), but the agency believes

that the plans are guiding national forest management (276). Others disagree, suggesting that the

agency has backed away from implementing some

forest plan decisions (205) or that the actions don’t

match the promises of the plans (76), Perhaps more

importantly, the monitoring and evaluation of activities and results has been inadequate to determine

whether forest plans are being implemented (i.e.,

whether budgets and actions are consistent with the

plan) and whether the results match the expectations.

(See ch. 6.)

A further problem in strategic planning is that line

managers often do not realize that planning is a

managerial function, that ‘ ‘planning and doing are

separate parts of the same job; they are not separate

jobs” (101, 241). Managers who have not been

involved in strategic planning commonly perceive

plans as a burden imposed on them, rather than as a

better way of doing business. The Forest Service has

found that forest plans are likely to work best—be

acceptable to the public and implemented by the

agency—if the forest supervisors were directly

involved in their development (276). However, the

forest planning process is complex and many

pressures compete for a manager’s time. Thus,

managers are often only marginally involved in the

planning process. Nonetheless, forest planning and

management must become integrated, and the Forest

Service is now providing training for forest supervisors and other employees on forest plan implementation.

Feedback and Control

Strategic planning is a continuous process, rather

than a discrete act. Because it directs an organization’s future, the strategic plan must be flexible

enough to respond to economic and political changes.

The Forest Service must also respond to natural

disasters—fires, floods, hurricanes, volcanic eruptions, etc. Thus, one should not expect NFMA

planning to be “done’ it is an ongoing process of

setting direction, of responding to feedback and to

changing conditions, and of guiding actions and

budget proposals. This is consistent with the NFMA

requirements to amend plans as needed and to revise

plans periodically.

Strategic planning requires that results—sales and

profits in business; outputs, uses, and conditions for

the national forests—be monitored to determine if

the actions meet the organization’s mission (241). If

the results are unexpected and undesirable-if all

the goals are not being achieved—actions can be

modified to achieve the defined goals, or the plan

amended to revise the goals, if necessary. Without

periodic evaluation, the organization could continue

in an unacceptable direction until litigation or some

other unanticipated event forces a change. Thus,

monitoring and feedback are essential to fulfilling

the strategic planning process. However, as discussed in chapter 6, the Forest Service has done very

little monitoring of forest plan activities.

Finally, strategic planning must be both centralized and decentralized in nature (101). It is centralized because the organization takes a comprehensive

look at its situation and overall direction. Furthermore, the control systems—such as budgeting and

performance appraisal-must be integrated and

coordinated, to assure that the various units can be

treated equitably. However, strategic plans must

also be decentralized, so that individual units are

appropriately distinguished and so that the managers

have the flexibility to respond to local situations and

are rewarded appropriately. The national strategic

planning 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 centralized

guidance for the agency. However, national production targets allocated to the national forests constrain

flexibility to respond to local physical, biological,

economic, and social conditions. Thus, forest planning must be consistent with the centralized guidance from RPA planning, but condition and output

targets and plan implementation and evaluation

must be decentralized, with each forest responding

to its local situation.

Poor coordination among units is a common

problem of strategic planning by corporations ( 101).

The Forest Service is basically organized functionally—by resource. This structure has served the

agency well for decades, but it inhibits integrated

resource management. For example, the first round

of forest plans was often reviewed in Forest Service

regional offices and the Washington headquarters by

resource staff specialists, who typically forced the

plans “back in line with the traditional singleresource’ approach (276,). Reorganizing the staff

and budget structures for integrated resource management was one of the future challenges identified

in the agency’s recent critique of its forest planning

process (276).

Another common strategic planning problem is

inadequate links to control systems, such as budgets

and incentives (101). Control systems guide performance. If the controls are inconsistent with the

strategic direction, they can slow or even prevent

successful implementation. In business, bonuses and

promotions are often based on specific accomplishments, outputs, or programs. If these targets do not

conform to the strategic goals, managers are more

likely to ignore the strategic goals than their

individual performance targets (241). Similarly,

budgets that are not consistent with the strategic

direction can shift management emphasis away from

that direction.

The Forest Service has addressed part of the

budget problem by calling for an integrated resource

budget process (276), but creating a link between

forest plans and annual budgets will require more

than a new budget structure (215, 217). (See ch. 8.)

Some critics of the agency have suggested that the

current budget system encourages timber harvesting

at the expense of other resources (187). Incentives

and rewards related to the forest plan are equally

important. Timber outputs have allegedly become so

important that many past and current employees

have expressed concern that the timber targets

override other resource considerations (66, 90, 136).

As discussed in chapter 9, strategic forest planning

requires that the Forest Service reward systems be

explicitly tied to preparing effective forest plans and

to implementing those plans.

SUMMARY AND CONCLUSIONS

Controversy has always surrounded the national

forests, The 1897 Forest Service Organic Act was

enacted principally to limit presidential authority to

establish reserves, and the authority to sell timber

was a subject of debate. In 1911, the U.S. Supreme

Court ruled that the Forest Service did have the

authority to regulate and charge for grazing in the

national forests. The Multiple-Use Sustained-Yield

Act of 1960 (MUSYA) was enacted at Forest

Service request, because of various efforts to reduce

discretion over managing the national forests. The

National Forest Management Act of 1976 (NFMA)

was enacted because litigation threatened to halt

clearcutting in the national forests, and thereby

reduce Forest Service timber sales by half. Today,

the controversies include debates about redcockaded woodpeckers, about spotted owls and

old-growth Douglas-fir forests, about below-cost

timber sales, and about the level of administrative

appeals and litigation. Controversies will probably

always exist, because people care about the lands

and resources of the National Forest System.

The national forests have always been managed to

provide multiple uses and sustained yields. MUSYA

further articulated the purposes for national forest

management, but did not establish unambiguous

goals for the national forests. The act presents a mix

of uses, outputs, resources, and land classes as

‘‘purposes, ’ without giving much guidance on how

to manage for the many uses and outputs. Multiple

use is to ‘‘meet the needs of the American people, ’

while sustained yield suggests limiting use to

sustainable levels. Taken together, the 1897 Organic

Act and MUSYA direct management of the national

forests to accommodate resource uses and produce

resource outputs in the mix that people want, while

protecting the lands and resources, and sustaining

the ecosystems. NFMA added considerations for

management and regulations for developing, amending, and revising the plans and for management

standards and guidelines, while requiring public

participation in defining the mix of resource values

for each national forest.
54 . Forest Service Planning: Accommodating Uses, Producing Outputs, and Sustaining Ecosystems

RPA established a strategic planning process for

the Nation’s natural resources. RPA, as amended by

the NFMA, also required the agency to prepare and

revise land and resource management plans for the

national forests. These plans can also be seen as

strategic plans, consistent with the guidance in RPA

and NFMA, with the purposes outlined in the

Organic Act and MUSYA, and with the public

disclosure required by the National Environmental

Policy Act of 1969 (NEPA).

Strategic planning establishes the direction for an

organization. Goals are measured in concrete terms

so that everyone (managers, employees, and the

public) understands the direction. As directed by

MUSYA, NFMA, and other laws, the national

forests are to accommodate uses and produce

outputs, while protecting lands and sustainin g ecosystems. (See ch. 4.) Forest plans must, therefore,

identify the quantity, quality, and timing of these

goals. A document that presents such a comprehensive picture of all uses, outputs, conditions, and sites

could be overwhelming to produce and to understand. Rather, the agency could present the management direction by describing how management

under the plan will change for key sites, important

outputs, and critical resources and ecosystems. In

essence, quantity and quality goals must be set for

the outputs and conditions people are concerned

about.

Strategic planning for the national forests must be

based on sound information and analysis, but is not

a precise, rational, scientific process. A Forest

Service review of criticisms concluded that national

forest planning is essentially political in nature (10),

and in its recent internal critique, the agency noted

that ‘‘technical answers to social and political issues

alienate many people’ (276). Technical answers

from computer programs were unlikely to be more

acceptable for directing national forest management

than was the professional expertise which had been

rejected in the early 1970s in the Bitterroot controversy, the Monongahela lawsuit, and the enactment

of NFMA. Strategic planning for government activities is rooted in public agreement-or working

consensus, informed consent, or whatever term you

choose to indicate that the management must be

acceptable to the public. (See ch. 5.) Public involvement can be most effective, if: 1) the decisions to be

made in the plan (and those to be postponed to

another time or forum) are specified when planning

is begun, and 2) the discussions and decisions focus

on the needs and concerns of the interested and

affected individuals and groups.

A strategic forest plan begins with an assessment

of the current situation-what people want and are

concerned about, and the land and resource conditions and trends that are relevant to those desires and

interests. More and better data will not ‘‘solve’

forest planning problems, because strategic planning

is not a rational, scientific process, but charting a

course to the desired destination (the goals) depends

on knowing the starting point. Inadequate data

hamper strategic planning by restricting understanding of current conditions and direction. Furthermore,

unless the data limitations are well known, technical

analyses based on poor data provide apparently

precise estimates of the consequences of various

options and opportunities. (See ch. 7.) The incomplete and outdated information used in the forest

plans, particularly on conditions- and impacts of

concern to the public, has impeded strategic forest

planning. (See chs. 6 and 8.)

If strategic planning is to have any value, the

forest plans must be implemented. The plans are

neither budget proposals nor ironclad commitments

to actions or results, particularly since government

agencies must request funds from a legislature. (See

ch. 8.) Strategic plans must allow for the flexibility

to respond to changing conditions, whether due to

budget restrictions, political changes, or natural

disasters. Nonetheless, the plans should guide budget

requests and management activities. It is unclear,

however, whether the forest plans are being implemented, because monitoring and evaluation of

activities and results has generally been inadequate.

(See ch. 6.) Plans are most likely to be implemented

if managers recognize that planning is part of the job

of managing a national forest, and are therefore

closely involved in the planning process. (See ch. 9.)

Finally, strategic planning is a continuous process, with feedback to assess plan implementation. If

the results differ unacceptably from those anticipated, the actions can be adjusted to achieve the

desired goals, or the plan can be amended to modify

the goals, if necessary. Without adequate monitoring, management could continue in an undesirable

direction until forced to change by unexpected

problems or litigation. (See chs. 5 and 6.)

A strategic planning process for the national

forests is both centralized and decentralized—

centralized for control and coordination, but decen-
Chapter 3—The Goals of National Forest Management and Planning . 55

tralized for flexibility to adapt to local physical,

biological, social, and economic conditions. Direction for national forest planning from the RPA

Program can provide the centralized coordination,

but should not impose rigid requirements that

hamper local flexibility. (See ch. 10.) Furthermore,

the agency’s traditional fictional organization

structure has inhibited the integrated, interdisciplinary approach required in planning and appropriate

in managing the lands and ecosystems, in assessing

plans and activities, and in dealing with the public.

(See ch. 9.) In addition, budgets and incentives must

be linked to the goals set forth in the plan; the current

budget system and performance appraisals emphasize commodity outputs over other use and condition

goals, but managers must be held accountable for

achieving all condition and output goals. (See chs.

8 and 9.)

Ultimately, managing the national forests is akin

to managing a trust fund. A trust fund is to provide

annuities for the beneficiaries, but the assets of the

trust are to be protected and enhanced. Similarly,

national forests are to be managed to provide the

values that people want-the uses, outputs, and

protection of special sites and resources. The assets

of the national forests—the lands, resources, and

ecosystems—are to be conserved and improved, to

assure that the values they provide can be sustained.

Strategic planning is an approach, consistent with

the laws governing the management of the national

forests, that can achieve these goals.
Chapter 4

The Legal Framework for Forest

Planning and Management
. . . . . .

Contents

Page

Setting Direction for Managing the National Forests . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . . . . . . 60

The Forest Service Organic Act . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .60

The Multiple-Use Sustained-Yield Act of 1960 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 61

The National Environmental Policy Act of 1%9 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 61

The Forest and Rangeland Renewable Resources Planning Act of 1974 . . . . . . . . . . . . . . . . . . 63

The National Forest Management Act of 1976 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 63

Additional Legal Constraints on the Forest Service . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 66

The Wilderness Act . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .66

The Wild and Scenic Rivers Act of 1%8 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 67

The Clean Water Act . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .70

The Endangered Species Act of 1973 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 70

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

Boxes

Box Page

4-A. Special Congressional Attention for the Tongass National Forest . . . . . . . . . . . . . . . . . . . . . 66

4-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 October 1989, Forest Service Chief Dale Robertson

asserted that forest management had become increasingly ‘‘complicated’ by the series of laws that

govern forest planning and plan implementation.

Chief Robertson stated that, while each law serves a

particular worthwhile purpose, taken together they

impose serious burdens on planning and implementation:

[T]rying to implement all of these laws does get

to be an extremely difficult situation . . .

Sometimes we feel like we are almost in an

impossible situation because when we face these

legal requirements of National Forest Management

Act, NEPA, Endangered Species Act, Archaeological Resource Protection Act, the Clean Water Act,

Clean Air Act, and all of these other laws,. . . people

can pick our weakest link, and challenge us on our

decisions, and delay or stop the best laid plans

(206).

Some critics question the utility and efficacy of

forest planning laws, believing these laws have not

contributed to solving problems related to resource

management, and even suggesting that the laws be

repealed (18, 187). They further charge that the

complex legal requirements have imposed a cumbersome and costly burden on the agency, subjecting it

to increased threat of appeals and litigation stifling

resource management, and accomplishing few of the

objectives it was designed to achieve (79). “Documentation, consistency, and correct procedure become far more important than a land manager’s

solid, experienced judgment” (16).

Others defend the current legal framework as

necessary to sustain the forest and rangeland ecosystems while accommodating uses and producing

outputs. Some argue that the current problems exist

because planning laws preserve too much agency

discretion, and urge Congress to mandate more

prescriptive management laws (76). The agency’s

current difficulties, they argue, result because the

agency has failed to follow the spirit and intent of the

existing environmental protection laws. Still others

suggest that numerous administrative appeals and

lawsuits result because the agency is not really

listening to the public (277); the legal requirements

might not seem so cumbersome, if the agency were

more responsive to local public input and worked

more closely with interested publics to solve conflict

through deliberation and negotiation.

This chapter examines the general framework of

laws governing land and resource management in

the national forests and the implications of each on

forest planning.1 First, it examines the laws that

primarily govern planning and management-the

Forest Service Organic Act of 1897, the MultipleUse Sustained-Yield Act of 1960, the National

Environmental Policy Act of 1969, the Forest and

Rangeland Renewable Resources Planning Act of

1974, and the National Forest Management Act of

1976. Then, it reviews certain laws that restrict

activities to protect various resource values2

--the

1964 Wilderness Act, the Wild and Scenic Rivers

Act of 1968, the 1972 Clean Water Act, and the

Endangered Species Act of 1973.

The chapter also briefly discusses the concern

over the ‘‘cumulative impact’ of these laws on

Forest Service planning and management. The

complex web of laws may make forest planning and

activities slower, costlier, and less efficient than

necessary to produce and protect the various resource values. Moreover, some laws guide the

setting of management direction based on local

conditions and public participation, while other laws

establish requirements or standards for specific

resources, values, or sites. The difficulties posed by

this legal web will be examined, but the thorough

legal 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 Fund

Act, the Archaeological Resource Protection Act, the Federal Land Policy and Management Act of 1976, the Clean Air Act Amendments of 1977, the

1978 American Indian Religious Freedom Act, the Public Rangelands Improvement Act of 1978, the 1980 Alaska National Interest Lands Consemation

Act, 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 Relaring

to 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 as

direction-setting laws, because management guidance is their primary purpose.

–59–

297-904 0 - 92 - 3
60 ● Forest Service Planning: Accommodating Uses, Producing Outputs, and Sustaining Ecosystems

structures could provide comparable protection more

efficiently is beyond the scope of this study.

SETTING DIRECTIO N

FOR MANAGIN G

THE NATIONAL FOREST S

Forest Service administration of the national

forests is authorized and governed by several

statutes that establish the agency’s mission and

generally define the scope of its regulatory and

management authority. These laws include the 1897

Organic Act, the Multiple-Use Sustained-Yield Act

of 1960 (MUSYA), the Forest and Rangeland

Renewable Resources Planning Act of 1974 (RPA),

and the National Forest Management Act of 1976

(NFMA). The following discussion examines how

each of these statutes has shaped the Forest Service’s

mission, the extent to which each directs the

substance and procedure of planning and decisionmaking, and the extent to which each has broadened

or narrowed the agency management authority and

discretion. In addition, because of its important

procedural requirements for forest planning, the

National Environmental Policy Act of 1969 (NEPA)

is also examined in this section.

The Forest Service Organic Act

In 1891, Congress gave the President the authority

to reserve by proclamation any public domain lands

“wholly or in part covered with timber or undergrowth, whether of commercial value or not . . ."3

This authority was narrowed in 1897 when Congress

defined the purposes for which such public lands

could be reserved. This act, which has become

known as the Forest Service Organic Act, provided

that:

No public forest reservation shall be established,

except to improve and protect the forest within the

reservation, or for the purpose of securing favorable

conditions of water flows, and to furnish a continuous supply of timber for the use and necessities of

citizens of the United States . . .

The forest reserves were created from public lands

under the jurisdiction of the General Land Office in

the Department of the Interior. Congress also

authorized the Secretary of the Interior to manage

and protect the lands by “mak[ing] such rules and

regulations and establishing] such service as will

insure the objects of such reservations, namely, to

regulate their occupancy and use and to preserve the

forests thereon from destruction” (89).

Early forest management focused primarily on the

timber and range resources. Management planning

for the forest reserves began in 1899, when the

Department of the Interior began developing working plans” for timber harvesting in each of the

established reserves (324). After the reserves and

management agency were merged into the Bureau of

Forestry in the Department of Agriculture in 1905,

the chief of the newly created Forest Service, Gifford

Pinchot, directed that working plans be developed

for every timber sale, in part to facilitate timber

harvesting, but also to avoid overcutting (324).

Forest Service planning and management of the

range resources began largely in response to the

perception that the public rangelands were being

overgrazed by sheep. Thus, while the early timber

planning efforts were to make timber available, the

early range management efforts were more regulatory in nature, designed to protect water and other

natural resources from the consequences of overgrazing (324). The agency charged fees for grazing

rights to reduce overgrazing on some lands and

withdrew certain other lands from grazing use

entirely. The Organic Act and these early resource

working plans firmly established both a utilitarian

and protective tradition for resource management

within the Forest Service, consistent with Chief

Pinchot’s views of proper resource management

(196, 324).

The agency’s authority to regulate the use and

occupancy of the national forests was first challenged by ranchers who objected to Federal control

over and fees for grazing livestock on traditionally

grazed lands. However, in 1911, the U.S. Supreme

Court upheld the agency’s authority to regulate

grazing through the imposition of “reasonable”

user fees (240). Of greater importance, the court

recognized that under the Organic Act the agency

possesses broad regulatory authority over the “occupancy and use” of the forest reserves. The court

held that the Secretary of Agriculture is required to

make rules and regulations to protect the forest

reserves ‘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 ‘‘to

regulate the occupancy and use and to preserve the

forests from destruction.”4

Since 1911, courts have consistently interpreted

the occupancy-and-use language of the 1897 Organic Act as providing the agency with broad

regulatory and management authority over the

national forest lands. Courts have recognized that

this authority includes, but is not limited to, the right

to issue land use permits for large areas,5 to regulate

motorized recreation use,6 and to regulate wildlife

within the national forests7 (324).

The Multiple-Use Sustained-Yield Act of 1960

MUSYA expanded the express regulatory and

management authority of the Forest Service. MUSYA

directed the Forest Service to administer the national

forests for “outdoor recreation, range, timber, watershed, and wildlife and fish purposes. ” (For a

discussion of these purposes, see ch. 3.) MUSYA

was intended to be consistent with the 1897 Organic

Act, and thus reflects and perpetuates the utilitarian

and protective visions embodied in the agency’s

traditions. In addition to recognizing principles of

multiple use and sustained yield, MUSYA provided

a clearer agency mission and established for the first

time a statutory basis for the concept of integrated

resource management. Nevertheless, MUSYA provided general guidance for national forest management without providing any specific substantive

direction on how to balance the various resources or

determine the appropriate mix of values generated

by the national forests.

Courts have consistently recognized that MUSYA

preserves the agency’s already broad regulatory

authority and wide discretion over the occupancy,

use, and protection of the forests. The Ninth Circuit

Court of Appeals has held that the language of the

MUSYA “breathe[s] discretion at every pore.”8

With MUSYA (and under the 1897 Organic Act),

it was difficult to challenge Forest Service management decisions successfully. The Monongahela

lawsuit successfully challenged long-standing Forest Service timber sale practices as violating specific

requirements in the Organic Act for selling timber.

However, agency discretion over management direction and the mix of resources values were

virtually unchallengeable.

The National Environmental Policy

Act of 1969

NEPA significantly altered the Forest Service’s

planning and management discretion. NEPA seeks

to assure that all Federal agencies will incorporate

environmental concerns into their decisionmaking

Processes.9 NEPA has been called ‘the first comprehensive commitment of any modern state toward the

responsible custody of the environment” (39).

Section 102(2)(C) of NEPA specifically requires

that all Federal agencies evaluate and prepare a

detailed written statement on the environmental

impact of all proposals “for legislation or other

major Federal actions significantly affecting the

quality of the human environment.” In 1978,

pursuant to an Executive order from President

Jimmy Carter, the Council on Environmental Quality promulgated regulations (40 CFR 1500-1508)

setting more specific standards and guidelines governing the “NEPA process. ” The regulations guide

when environmental impact analyses and statements

are required, direct that alternatives to the proposed

action be evaluated, and set forth general standards

for those processes.

The U.S. Supreme Court has held that NEPA has

two objectives: 1) to obligate agencies to consider

the 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 this

act 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. United

Stares, 443 F. 2d 452 (9th Cir 1971).

gsection 2 of MAspecitles that the purposes of the aCt me: “To declare a national policy which will encourage productive and enjoyable harmony

between man and his environment to promote efforts which will prevent or eliminate damage to the environment and biosphere and stimulate the health

and 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).
62 ● Forest Service Planning: Accommodating Uses, Producing Outputs, and Sustaining Ecosystems

agency has considered an action’s environmental

consequences.

10 The Court has also held that NEPA

is a procedural rather than a substantive law, i.e., that

it does not mandate certain outcomes or decisions. If

an agency fully complies with the law’s procedural

requirements, the agency cannot be forced to modify

its decision based on likely environmental effects or

to mitigate those environmental impacts.11 The

procedural nature of NEPA has complicated its

implementation, however, because the detailed NEPA

requirements have largely evolved as “common

law” in the Federal courts. To ensure that planning

and decisionmaking procedures comply with NEPA

standards, agencies must frequently consult an

extensive and growing body of case law.

NEPA has had an extensive, though indirect,

effect on national forest management. NEPA does

not alter the Forest Service’s mission, nor specifically narrow the agency’s management and regulatory authority and discretion. It neither mandates

certain mixes or combinations of resource values,

nor requires the agency to select the most environmentally sound alternatives to proposed actions.

Nonetheless, the impact of the extensive and complex NEPA procedures on agency decisionmaking

should not be underestimated. NEPA has affected

Forest Service planning and decisionmaking in two

basic ways, consistent with the objectives of the act:

consideration of environmental impacts, and full

public disclosure.

The Forest Service has long considered the

balance among resource uses in its planning and

decisionmaking; MUSYA merely confined a longstanding Forest Service tradition of considering

resource tradeoffs. However, by requiring an assessment of environmental impacts, rather than just a

balance among uses, NEPA added environmental

protection (over and above the MUSYA requirement

to maintain the productivity of the land) as a

consideration in national forest management. NEPA

served as a catalyst for the integrated planning and

management contemplated 10 years earlier by MUSYA

(1, 324). Section 102(2)(a) of NEPA directs the use

of an interdisciplinary approach in Federal planning

and decisionmaking. This direction (together with

similar direction in NFMA) has changed the agency’s

decisionmaking processes at all levels, and has

prompted the agency to replace its traditional

resource planning with planning for coordinated

resource management (l). The requirements for

interdisciplinary planning have also brought a more

diverse collection of professionals to the agency.

The other significant impact on Forest Service

planning and management is the full disclosure

requirement. In response to NEPA, the Forest

Service began to expand its public information and

participation programs drastically (1, 231), and this,

in turn, has meant closer public scrutiny. Furthermore, the agency’s compliance with NEPA procedures are subject to closer judicial scrutiny than are

decisions under management guidance. In 1976, the

U.S. Supreme Court noted that courts will take a

“hard look’ at agency consideration of environmental impacts under NEPA, to assure that the

decisions are not arbitrary and capricious.12 Thus,

through the closer public and judicial scrutiny of

agency decisionmaking, NEPA has effectively required the Forest Service to keep a detailed and

thorough record of its decisionmaking processes.

Finally, NEPA requires that environmental analyses be site-specific. This is difficult in forest

planning, because the plans do not set forth specific

activities and sites; such details are determined in

project (or implementation) planning. Nonetheless,

forest plans are required to be consistent with NEPA.

The Forest Service now views the environmental

impact statement accompanying the plans as ‘‘programmatic," assessing the impacts of the programs

(the plans). Site-specific environmental analyses

conducted for specific projects are ‘‘tiered’ to the

programmatic environmental impact analyses, without repeating the programmatic analyses.13 In part

because programmatic analyses can be several years

old, agencies must supplement them when significant new information becomes available. Thus,

forest and project planning and NEPA analyses are

parts 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 ~SFS

my 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.
Chapter 4--The Legal Framework for Forest Planning and Management . 63

The Forest and Rangeland Renewable

Resources Planning Act of 1974

Congress enacted RPA to reassert its authority

over Forest Service planning and decisionmaking.

RPA applies to all four branches of the agency—the

National Forest System, State and Private Forestry,

Research, and International Forestry-and directs

the agency to develop a long-term strategic planning

process (259). As part of this strategic planning

process, RPA required land and resource management plans for units of the National Forest System.

However, except for requiring a “systematic interdisciplinary approach ‘‘ in developing these plans,

RPA provided no substantive or procedural standards and guidelines for their development, until it

was amended by NFMA in 1976.

The National Forest Management Act of 1976

NFMA established a complex series of procedural

and substantive requirements for developing the

long-term land and resource management plans

(forest plans) required by RPA. Although NFMA

neither modifies the principles of MUSYA nor

directs any particular balance or mix of resource

values, the extensive planning requirements have led

some to dub it the agency’s ‘‘new Organic Act’

(324). By setting forth a host of procedural and

substantive standards and guidelines for planning

and implementation, NFMA significantly affects

Forest Service management and to some extent

narrows the agency’s regulatory and management

discretion.

NFMA does not mandate specific output levels,

determine the mix of values produced, or attempt to

set priorities for resource managers. While embracing MUSYA, NFMA provides more substance to the

principles of multiple use and sustained yield, and

consequently offers additional guidance to the

agency on forest planning. NFMA establishes a

planning process to set goals and objectives for

national forest management and to identify: 1)

standards and guidelines for management, 2) proposed and possible activities, and 3) the necessary

financial resources.

NFMA serves three basic functions. First, it

directs the agency to prepare long-term integrated

forest plans for each national forest, to be amended

or revised as needed, but revised at least every 15

years. Next, it requires regulations establishing

substantive standards and guidelines for timber

management and for the protection of water and

other renewable resources. And finally, it expressly

provides for active public involvement in the planning process. The following discussion examines

these functions, and discusses their implications for

managers.

Developing National Forest Plans

The forest planning process is comprised of three

components: development, approval, and implementation. Section 6(f)(5) of NFMA directed the

Forest Service to attempt to complete the initial

round of forest plans by September 30, 1985, and to

revise each plan at least every 15 years. When

developing forest plans, the agency is required to

adhere to the principles of MUSYA and to follow the

procedural requirements of NEPA. NFMA embraces

the concept of integrated planning through interdisciplinary analysis; each national forest shall employ

an interdisciplinary planning team (section 6(f)(3))

to use a “systematic interdisciplinary approach to

achieve integrated consideration of physical, biological, economic, and other sciences’ (section 6(b)).

Plans must be based on “inventory data on the

various renewable resources’ of the forest (section

6(g)(2)(B)). NFMA also directs that implementing

regulations specify guidelines for forest plans to

ensure that plans achieve the goals of the RPA

program (section 6(g)(3)).

Once a plan has been developed (with public

involvement), it must be approved by the regional

forester who, after reviewing the plan, must submit

a Record of Decision. If approved, the plan becomes

final and implementation can begin. Under Forest

Service regulations (36 CFR 217), final forest plans

are subject to administrative appeals—an additional

administrative review initiated by members of the

public. (See ch. 5.) Plans are also subject to legal

challenge, under the Administrative Procedures Act,

since NFMA contains no specific provision for

judicial review of forest plans.

Forest plans are developed using the principles of

strategic planning-setting direction, developing

targets for outputs and conditions, and establishing

standards and guidelines for implementation. (See

ch. 3.) Plans are generally programmatic in nature;

rather than making site-specific decisions on uses

and outputs, plans set general goals and guidelines,

which direct activities on the ground. Nonetheless,

section 6(f)(2) of NFMA also requires the plans to

reflect ‘‘proposed and possible actions, including
64 ● Forest Service Planning: Accommodating Uses, Producing Outputs, and Sustaining Ecosystems

the planned timber sale program . . . necessary to

fulfill the plan.” The plan does not make such

project decisions, but does set goals and objectives,

establish management standards and guidelines, and

identify management prescriptions (scheduled combinations of activities for management areas), and

subsequent project decisions must be consistent with

the plan.

Until they are amended or revised, final forest

plans are the primary guidance for Forest Service

actions on the ground. NFMA provides that if an

amendment would result in a‘‘signiilcant change, ’

the agency must provide for public involvement

comparable to that allowed for plan development

(section 6(f)(4)). Entire plans shall be revised when

the agency finds that conditions on a forest ‘‘have

significantly changed, ” but at least every 15 years

(section 6(f)(5)). Whether such changes are “significant‘‘ is to be determined at the discretion of the

agency. Pursuant to NFMA, the Secretary of Agriculture promulgated regulations in 1979 (revised in

1982), which set forth specific procedures for

resource inventorying and monitoring, and for plan

development and implementation. The Forest Service has begun the process of revising the planning

regulations, with the ‘Advanced Notice of Proposed

Rulemaking" published in the Federal Register on

February 15, 1991.

Guidelines for Timber Management and for

Resource Protection

Although NFMA is primarily a procedural law, it

does require regulations setting forth substantive

standards and guidelines. Most of the substantive

requirements apply to timber management practices,

while the others generally provide guidance for

protecting water, plant, and animal resources. Many

of these provisions narrow the agency’s management discretion to various degrees.

Because NFMA was passed largely in response to

litigation over the agency’s timber management

practices, it is no surprise that much of the law is

focused upon regulating those practices. NFMA

includes provisions that limit the location, methods,

and amount of timber production that may take place

within the national forests. NFMA requires regulations that specify that:

1. increases in harvest levels are based on intensified management practices, only if such practices can be done in accordance with MUSYA

2.

3.

4.

5.

6.

7.

and are successfully implemented (section

6(g)(3)(D));

timber harvesting is allowed only on those

lands where “soil, slope, or other watershed

conditions will not be irreversibly damaged”

(section 6(g)(3)(E)(i));

timber harvesting is allowed only where there

is ‘assurance that such lands can be adequately

restocked within 5 years” (section 6(g)(3) (E)(ii));

“protection is provided for streams, lakes,

shorelines, and other wetlands from detrimental changes” from timber harvesting (section

6(g)(3) (E)(iii));

the harvesting system ‘‘is not selected primarily because it will give the greatest dollar return

or the greatest unit output of timber’ (section

6(g)(3) (E)(iv));

clearcutting is used where “it is determined to

be the optimum method . . . to meet the

objectives and requirements of the relevant

land management plan” (section 6(g)(3)(F)(i);

and

‘‘maximum size limits for areas to be cut in one

harvest operation” are established (section

6(g)(3) (F)(iv).

NFMA also generally prohibits the sale of timber

from lands identified as not suited for timber

production and generally limits sales to sustainable

levels. Specifically, section 6(k) prohibits timber

harvesting on lands identified as:

. . . not suited for timber production, considering

physical, economic, and other pertinent factors to the

extent feasible . . . except for salvage sales or sales

necessitated to protect other multiple-use values . . .

Section 14(a) directs the Secretary to:

. . . limit the sale of timber from each national forest

to a quantity equal to or less than a quantity which

can be removed from such forest annually in

perpetuity on a sustained-yield basis . . .

The annual sale quantity is allowed to fluctuate

above and below the average for each decade. A plan

can also depart from this ‘non-declining even flow’

level of timber harvesting, if the departure is

‘‘consistent with the multiple-use management objectives . . . [and] made with public participation. ’

Many of the evaluations and determinations

admittedly require the professional judgment of

agency personnel, and thus are substantially discretionary in nature. Nevertheless, these provisions
Chapter 4--The Legal Framework for Forest Planning and Management . 65

establish a mandatory framework for making decisions on timber harvesting, and consequently limit

to some degree the traditional discretion of the

agency to regulate and manage timber harvesting.

The various provisions that constrain timber

management were enacted to limit the impacts of

timber harvesting on other forest resources. Congress appeared especially concerned about the potential impacts of logging practices on water and

fisheries. NFMA contains other provisions aimed at

protecting resources from impacts of timber harvesting, mineral development, recreation, and other uses

on forest resources. Section 6(g)(3)(B), for example,

directs that forest plans should protect biological

diversity within the national forests. 14 Specifically,

the regulations for forest planning should include

guidelines to:

. . . provide for diversity of plant and animal

communities based on the suitability and capability

of the specific land area in order to meet overall

multiple-use objectives . , .

Section 6(g)(3)(C) essentially requires research

and evaluation, through continuous monitoring and

field assessment of the effects of management, to

ensure that the productivity of the land is not substantially and permanently impaired.

Public Involvement

The third basic function of NFMA is to provide

for active public involvement. NFMA (in conjunction with NEPA) seeks to assure that before proceeding with certain actions and programs, the agency

informs and involves the public in decisionmaking.

By opening up the agency’s decisionmaking processes to closer public and congressional scrutiny,

NFMA has increased agency accountability and

decreased discretion. (See ch. 5).

Implications for Managers

NFMA and the other direction-setting laws provide guidance for establishing output and condition

targets for the national forests and standards and

guidelines for management with public participation. In forest planning, the agency must consider

alternative approaches for managing the lands and

resources, and must evaluate the potential sitespecific and cumulative impacts of management

options. Failure to comply with NFMA procedures

can prevent the agency from proceeding with a

particular action. NEPA seeks to assure that environmental considerations become an integral part of

decisionmaking, and NFMA adds the requirement

that actions be implemented in a manner that does

not seriously impair the forest lands, resources, or

productivity.

The actual impacts of NFMA on Forest Service

management discretion cannot be known precisely.

While the law requires regulations constraining the

use of certain practices that might have significant

adverse impacts, the determin ation of significance is

largely a matter of agency discretion. In addition,

courts remain relatively deferential to the agency’s

management discretion under NFMA. In one example, the court acknowledged that soil erosion from a

proposed road construction would have major consequences on the water of a nearby stream, but

upheld the agency’s decision to proceed with the

project as planned, stating that, “[l]ike the Multiple

Use, Sustained Yield Act [sic], the NFMA requires

that national forest lands be managed with due

consideration given to environmental values . . .

Here, the balancing of competing values struck by

the Forest Service . . . was not so insensitive to

environmental concerns that it violates the NFMA."15

Relatively few court decisions have interpreted

agency discretion under NFMA since the initial

forest plans have been completed. Thus, it may be

premature to speculate on the degree to which courts

will defer to agency management discretion in the

future. However, the numerous procedural and

substantive NFMA requirements for forest planning

make more agency decisions subject to administrative and judicial review. It is possible that the

administrative and judicial challenges to agency

plans and decisions will be unprecedented. The

precise impacts of the threat of appeals and litigation

on agency decisionmakers is unknown, but it is

indisputable 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 ecosystem

diversity for the natiorud forests. The regulations go further, su~esting species diversity by requiring that “fish and wildlife habitat shall be managed

to maintain viable populations of existing native and desired non-native vertebrate species” (36 CFR 219.19). In this report, biological diversity in

national 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).
66 ● Forest Service Planning: Accommodating Uses, Producing Outputs, and Sustaining Ecosystems

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

documenting decisions.

ADDITIONAL LEGAL

CONSTRAINTS ON THE

FOREST SERVICE

The laws examined above set out the general

planning and management framework for the Forest

Service. Most of these laws are procedural in nature

and provide only general guidance to the agency on

how to balance resource management. In addition to

these laws, numerous statutes not specifically written for the national forests circumscribe forest

planning and management. The purposes of these

laws are typically to protect particular resources or

sites, and thus the laws frequently impose substantive constraints or limitations on activities. (See box

4-A.) This section describes the four major resource

management. 16

The Wilderness Act

The Wilderness Act, enacted in 1964, maybe the

most law most restrictive to Forest Service management discretion, because it prohibits or restricts

various uses in particular areas of the national

forests. The purpose of the act is to preserve natural

areas for recreation and other purposes. Lands are

included in the National Wilderness Preservation

System by act of Congress from those Federal lands

where:

. . . the earth and its community of life are untrammeled by man, where man himself is a visitor who

does not remain. An area of. . . undeveloped Federal

land retaining its primeval character and influence,

without permanent improvements or human habita-

]~~o~forests ~ont~ o~y N.systas ofsw~ ~mgement ~~ — tie Natio~ Wildern=s Preservation System and the National Wild

and Scenic Rivers System. The national forests also contain numerous other special management areas, typically designated by Congress individually

and 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 to

preserve its natural conditions (section 2(c)).

Congress did not view designated wilderness

areas within national forests as conflicting with the

general direction for national forest management.

Section 4(a)(1) of the Wilderness Act specifically

states that:

. . . [n]othing in this Act shall be deemed to be in

interference with the purpose for which the national

forests are established as set forth in the Act of June

4, 1897 [the Forest Service Organic Act], and the

Multiple-Use Sustained-Yield Act of 1960.

Despite such statements, the Wilderness Act

effectively limits Forest Service discretion for managing designated wilderness areas within the national forests. Section 4(b) states that:

. . . each agency administering any area designated

as wilderness shall be responsible for preserving the

wilderness character of the area and . . . wilderness

areas shall be devoted to the public purposes of

recreational, scenic, scientific, educational, conservation, and historical uses.

To achieve these purposes, section 4(c) expressly

prohibits commercial enterprise, permanent or temporary roads, motorized and mechanical transport,

and structures and installations in wilderness areas,

except for existing private rights and minimum

administrative requirements. However, the Wilderness Act also provides numerous exemptions to

these restrictions:

1.

2.

3.

4.

motorboat and aircraft access “may be permitted to continue, ’ where such use existed prior

to 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 gathering

on other resources is permitted ‘if such activity

is carried on in a manner compatible with the

preservation of the wilderness environment”

(section 4(d)(2));

activities under valid existing mineral rights

(which could be established on or before

December 31, 1983) ‘‘necessary in exploring,

drilling, producing, mining, and processing

operations’ are permitted, ‘‘subject to such

reasonable regulations governing ingress and

egress as maybe prescribed” (section 4(d)(3));

5. the President may authorize water and power

projects, and associated activities, “needed in

the public interest” (section 4(d)(4)(l));

6. livestock grazing ‘‘shall be permitted to continue subject to such reasonable regulations as

are deemed necessary’ (section 4(d)(4)(2));

and

7. “commercial services may be performed . . .

for activities which are proper for realizing the

recreational or other wilderness purposes of the

areas” (section 4(d)(6)).

In addition, many of the subsequent statutes

adding areas to the National Wilderness Preservation System have established similar exceptions for

particular sites and activities, typically to permit

existing uses to continue after the areas have been

designated.

Nonetheless, the Wilderness Act clearly limits

agency activities in planning and managing the

designated areas. (See box 4-B.) Despite the numerous exemptions from the general restrictions, certain

uses—most notably timber harvesting and developed recreation—are prohibited in wilderness areas.

Furthermore, even for the exemptions, the agency is

restricted as to the location and extent of permissible

activities. Thus, the Wilderness Act significantly

narrows Forest Service management discretion, and

limits choices available in national forest planning

for designated areas.

The Wild and Scenic Rivers Act of 1968

The Wild and Scenic Rivers Act of 1968 is

intended to preserve and protect the unique values of

certain rivers and their surrounding lands. Specifically, section l(b) of the act directs that selected

rivers with ‘‘outstandingly remarkable scenic, recreation, geologic, fish and wildlife, historic, cultural,

or other similar values, be preserved in free-flowing

condition, and that they and their immediate environments shall be protected for the benefits and

enjoyment of present and future generations. ’ The

act requires agencies (including the Forest Service)

to report to the President on the suitability or

nonsuitability of rivers within their jurisdiction for

addition to the National Wild and Scenic Rivers

System, and the President makes recommendations

to Congress. Congress then designates components
68 ● Forest Service Planning: Accommodating Uses, Producing Outputs, and Sustaining Ecosystems

ITIW porest service had administratively created a system of wildeme% VVML ti ptitive m~in 1924. The Wilderness

Act established the National Wilderness Preservation System with the existing 9.1 million ams of administratively designated wilderness and

wild 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 specified

and 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 and

designated rivers. The agency charged with admini- scenic rivers system shall be administered in such

stering the river is directed to establish boundaries reamer as to protect and enhance the values which

17~ ~n~tt.heNatio~ Wilderness ~eservation systemwhere ody Congress can designate areas, State legislatures can designate dditiOnS tO

the National Wild and Scenic Rivers Systeu with the approval of the U.S. Secretary of the Interior.
Chapter 4--The Legal Framework for Forest Planning and Management ● 69

caused it to be included in said system without, such areas . . . as may be necessary to protect such

insofar 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 scheduled

enjoyment of these values. In such administration timber harvesting, road construction, and similar

primary emphasis shall be given to protecting its activities which might be contrary to the purposes of

esthetic, scenic, historic, archaeological, and scien- this Act.

tific features. Management plans for any such

component 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 prospecial attributes of the area. scriptive; rather it allows the Forest Service to

determine what management goals and activities are

Section 12(a) then adds that each agency: consistent with the purposes of the act. Nonetheless,

shall take such action respecting management 0.. the act does emphasize management for esthetic,

policies, regulations, contracts, [and] plans, affecting scenic, historic, archaeological, and scientific val-
70 ● Forest Service Planning: Accommodating Uses, Producing Outputs, and Sustaining Ecosystems

ues, and requires protecting and enhancing the

values that led to the river being designated.

Consequently, Forest Service discretion in planning

for the management of these areas is narrowed

significantly.

The Clean Water Act

Congress established stricter standards for protecting the Nation’s water resources in 1972 when it

revised the Federal Water Pollution Control Act,

also known as the Clean Water Act.18 The purpose

of the Clean Water Act is to enhance water quality

by imposing limitations on sources of pollution. The

act allows States to set their own water quality

standards, equal to or more restrictive than the

Federal standards, and requires Federal agencies to

comply with the State standards.

The Clean Water Act provisions having the

greatest impact on Forest Service management are

those regulating nonpoint source pollution. Unlike

point source pollution, which originates from a

discrete, identifiable source such as a ditch or pipe,

nonpoint source pollution refers to pollution originating over a widespread land area, such as from

agricultural, mining, or silvicultural activities. National forest activities that might generate nonpoint

source pollution include, but are not limited to,

timber harvesting, livestock grazing, off-road vehicle use, and road and trail construction and maintenance.

The Clean Water Act was amended in the Water

Quality Act of 198719 to require the States to develop

standards for regulating nonpoint source pollution.

When combined with the requirement for Federal

agencies to comply with State water quality standards, the State standards for nonpoint source pollution become a critical consideration for the Forest

Service (6). While NEPA only requires the Forest

Service to evaluate and consider the impacts of

management activities on watersheds and water

quality, the Clean Water Act prohibits the agency

from engaging in activities that would cause impacts

in excess of Federal or State water quality standards.

Thus, Federal and State water quality laws impose

substantive, enforceable limits on national forest

management—the State water quality standards

represent a minimum level of protection, which the

Forest Service must observe. Consequently, in forest

planning, the Forest Service is not allowed the

discretion simply to weigh the impacts on water

quality against the anticipated benefits from a

particular use.

The Forest Service has attempted to meet State

water quality standards by requiring forest plans to

include Best Management Practices (BMPs) for

protecting water quality. However, courts have ruled

that, even when the U.S. Environmental Protection

Agency and the relevant State agency approve the

BMPs, the use of BMPs does not guarantee compliance with State water quality standards .20 BMPs are

only a means to achieve those standards, not a

replacement for the standards (6, 7). The Forest

Service must not only plan to use BMPs, but must

also show that their practices comply with State

water quality standards. Thus, the Clean Water Act

substantially narrows agency discretion.

The Endangered Species Act of 1973

The Endangered Species Act of 1973 (ESA) is

another environmental protection law with potentially serious implications for forest planning and

management. As is apparent in the current controversies over the northern spotted owl in the Pacific

Northwest and the red-cockaded woodpecker in the

Southeast, the designation of a plant or animal

species as threatened or endangered under ESA can

alter Forest Service planning considerations and

management discretion.

ESA recognizes that various species of fish,

wildlife, and plants “have been so depleted in

numbers that they are in danger of or threatened with

extinction” (section 2(a)(2)), but they are of “esthetic, ecological, educational, historical, recreational, and scientific value” (section 2(a)(3)). The

purposes of the act are to provide: 1) a mechanism

for conserving ‘‘the ecosystems upon which endangered species or threatened species depend,’ and 2)

a program for conserving those species (section

18~e Feder~ water pollutioncon~olfit had b~n erected ~194* (~t of J~e 30, 19@, Ch. 75* (62 stat. 1155)) and amended numerous timeS

prior to its complete revision in the Federal Water Poilution Control Aet Amendments of 1972. This revision was subsequently amended in the Clean

Water 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’d

in 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 as

bringing “any endangered species or threatened

species to the point at which the measures provided

pursuant to this act are no longer necessary’ (section

3(3)). Thus, for ESA, conservation is synonymous

with recovery of the species.

ESA is administered by the U.S. Fish and Wildlife

Service (USFWS) and the National Marine Fisheries

Service (NMFS). Section 4(a)(1) of the act requires

USFWS and NMFS to determine if species are

threatened or endangered by: 1) destruction or

modification of habitat, 2) overutilization, 3) disease

or predation, 4) inadequate regulatory mechanisms,

or 5) other natural or human factors. The determination is to be based ‘‘solely on the best scientific and

commercial data available” (section 4(b)(l)(A)).

Congress gave specific directions not to include

economic effects in determining if species are

threatened or endangered; the report on the 1982

ESA amendments from the House Committee on

Merchant Marine and Fisheries states:

The addition of the word “solely” is intended to

remove from the process of the listing or delisting of

species any factor not related to the biological status

of the species. The Committee strongly believes that

economic considerations have no relevance to determinations regarding the status of species and intends

that economic analysis requirements . . . not apply

(258).

Section 4(a)(3)(A) requires the designation of

“any habitat of such species which is then considered to be critical habitat. Critical habitat is also to

be based on the best scientific data available, but in

contrast to the listing decision, the USFWS or

NMFS is to consider ‘the economic impact, and any

other relevant impact, of specifying any particular

area as critical habitat” (section 4(b)(2)).

ESA establishes three considerations of endangered or threatened species for national forest

planning and management. First, a recovery plan is

to be developed for endangered and threatened

species (section 4(f)), focusing on species that

‘‘conflict with construction or other developmental

projects or other forms of economic activity. ” The

services of ‘appropriate public and private agencies

and institutions, and other qualified individuals’ are

to be procured, but recovery teams are exempt from

the Federal Advisory Committee Act (FACA).

When national forest lands are involved, Forest

Service employees are likely to be included in

recovery planning teams, and thus, recovery plans

and 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 designated

as endangered. “Taking” is defined to mean “to

harass, harm, pursue, hunt, shoot, wound, kill, trap,

capture, or collect, or to attempt to engage in any

such conduct” (section 3(18)). Section 10 defines

conditions under which the taking of an endangered

species would be permitted.

Finally, section 7(a)(2) of ESA directly affects

Federal agency actions by specifying that:

Each Federal agency shall, in consultation with

and with the assistance of the Secretary [of Interior

and of Commerce], insure that any action authorized,

funded, or carried out by such agency. . . is not likely

to jeopardize the continued existence of any endangered species or threatened species or result in the

destruction or adverse modification of [critical]

habitat . . .

Following the consultation, the Secretary is to

issue an opinion on whether the actions will

jeopardize the endangered or threatened species or

will adversely modify the designated critical habitat.

If jeopardy or adverse modification is identified, the

Secretary must then suggest a reasonable alternative

for achieving the results without jeopardizing the

species 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 statement

setting forth the Secretary’s opinion, and a summary

of the information on which the opinion is based,

detailing how the agency action affects the species or

its critical habitat. If jeopardy or adverse modification is found, the Secretary shall suggest . . .

reasonable and prudent alternatives . . .

The Endangered Species Act could have serious

implications for Forest Service management and

planning. Recovery plans can affect national forest

plans, since NFMA requires forest plans to be

‘‘coordinated with the land and resource management planning processes of . . . other Federal agencies” (section 6(a)). Furthermore, any action that

constitutes a‘ ‘taking’ under ESA is strictly prohibited. Finally, the Forest Service is required to consult

with the Fish and Wildlife Service on plans and

activities that might jeopardize threatened or endangered species or that might adversely modify critical
72 ● Forest Service Planning: Accommodating Uses, Producing Outputs, and Sustaining Ecosystems

habitat. Because of the programmatic and strategic

nature of forest planning, it is virtually impossible to

determine in advance whether particular management activities under the plan will lead to a finding

of jeopardy or adverse modification. Thus, the

section 7 consultation process is an ongoing one. To

the extent that national forest plans and activities

conflict with ESA’s requirements, amendments

and/or revisions to the plans may be necessary.

SUMMARY AND CONCLUSIONS

The 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 Forest

Service Organic Act, the Multiple-Use SustainedYield Act of 1960, the Forest and Rangeland

Renewable Resources Planning Act of 1974, and the

National Forest Management Act of 1976. These

laws essentially create an open planning process

through which values are balanced and tradeoffs are

evaluated in national forest management. The National Environmental Policy Act of 1969 augments

these direction-setting laws by requiring the Forest

Service to consider environmental impacts and to

show the public how those impacts were considered.

The protection-standards laws typically apply to

much more than just the Forest Service, and

establish standards for protecting particular resources or sites. Some of the most important ones for

national forest planning and management include

the Wilderness Act, the Wild and Scenic Rivers Act

of 1968, the Clean Water Act, and the Endangered

Species Act of 1973. These statutes differ from the

direction-setting laws, because they are not premised on balancing resource values, but on maintaining minimum standards for resource or site

protection. Furthermore, these laws were passed at

different times over the past few decades, and serve

different, sometimes overlapping or even contradictory, purposes. Nonetheless, because these laws

establish specific standards or restrictions, the Forest

Service must comply with their legal requirements.

The complex web of laws, some requiring a

balancing of values and others establishing standards or restrictions, has raised two concerns. The

frost, articulated by Forest Service Chief Dale

Robertson, is that the numerous compounding and

possibly conflicting requirements make national

forest planning and management an exceedingly

complicated task. At the extreme, the sum total of

the various protection standards and restrictions may

make any on-the-ground management actions infeasible.

To date, the “cumulative impact” of the various

laws on Forest Service management has not been

extensively analyzed, nor is it known whether the

collective purposes of these laws can be realistically

achieved while maintaining historic levels of national forest uses and outputs. However, such legal

analyses are beyond the scope of this study. Congress could consider commissioning such analyses

by an independent organization with the necessary

legal expertise. Congress could even consider modifying the protection-standards laws for national

forest management, to allow the goals of these laws

to be balanced with other values in national forest

planning. Again, however, analyzing the implications of such an option is beyond the scope of this

study and of OTA’s mandate.

The second concern is that the complexity of the

legal framework, and especially of the process laws

such as NFMA and NEPA, lead agency managers to

focus on "bomb-proofing" their management plans.

Planning must follow correct procedures and be

thoroughly documented, and decisions must be

consistent—regardless of the validity, appropriateness, or acceptability of the plans and decisions—

because proper procedure, documentation, and consistency are necessary to demonstrate that the

decisions are not arbitrary and capricious (16).

This concern is predicated on two assumptions.

The first is that the judicial system examines only

whether the agency has followed the letter of the

law. When agencies are sued, the courts do rule on

whether agencies have fulfilled their legal requirements, especially for laws with specific standards or

constraints. For example, the Forest Service must

meet State water quality standards, and it must

consult with the Fish and Wildlife Service (or

NMFS) when its actions might affect an endangered

species. However, courts also grant substantial

deference to an agency when the laws grant discretion to the agency. For example, the Forest Service

must consider the relative values of the various

resources, and must consider physical and economic

factors in identifying lands not suited for timber

production. For forest planning, the Forest Service

should identify the legal requirements that must be
Chapter 4--The Legal Framework for Forest Planning and Management ● 73

fulfilled, prior to considering alternative management direction for the national forests.

The second assumption underlying the perceived

need for bomb-proofing is that various interests will

sue if their desires are not met in forest planning.

However, this assumption is inaccurate, in two

respects. First, the Forest Service is facing relatively

few lawsuits. In fiscal year 1989, only 11 of

approximately 500 forest plan appeals and only 32

of 525,000 timber sales were litigated (300). (See ch.

5.) Second, and more importantly, people typically

sue only if they believe the agency is being arbitrary

or unfair. Such beliefs can generally be overcome

through an open, honest exchange of desires and

concerns among the agency and the various interested and affected individuals and groups, leading to

understanding and acceptance of the possibilities

and limitations for managing the national forests.

This is the purpose behind NFMA’s requirement for

public participation in national forest planning.
Chapter 5

Public Involvement

in Forest Planning
Contents

Page

public Participation in Forest Service Planning . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ’77

Legal Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 77

Forest Service Efforts in Public Participation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 81

Reducing Conflict Through Cooperation and Collaboration . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 86

Administrative Appeals and Litigation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .95

Administrative Appeals . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . 95

Litigation 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

101

101

102

103

103

104

105

105

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 substantial

role for the public in forest planning than had

previously existed. Its public participation requirements complemented those already in place under

the National Environmental Policy Act of 1969

(NEPA). Congress assumed that a more participatory planning process would lead to better, more

acceptable management of the national forests, and

that early and continual public involvement could

help the agency resolve controversies in a more

organized and timely fashion.

Despite NFMA, many conflicts and controversies

over the management of the national forests remain.

In October 1989, the Senate Committees on Agriculture, Nutrition, and Forestry and on Energy and

Natural Resources convened a joint oversight hearing to review the planning process under NFMA.

Several senators expressed frustration over the

continuing controversies, and concern that many

were being resolved outside of the planning process—

in annual appropriations or in administrative appeals

or litigation. In his introductory remarks, Senator

Patrick Leahy (Vermont) stated:

I have been very concerned with the process in

which forest controversies in the Northwest are

being resolved; not in the planning process; not in

the courts, but through the appropriations process by

means of limiting judicial review (143).

Senators Mark Hatfield (Oregon) and James

McClure (Idaho) concluded that the planning process had ‘‘broken down. ’ Prescriptions for reforming

the current system vary widely, but the problem is

commonly attributed to Forest Service failure to

involve the public effectively in forest planning.

The legal and regulatory framework for public

participation in forest planning is designed to

encourage public involvement in three general

stages of the process: 1) in plan development,

review, and implementation; 2) through requests for

administrative review of plans and decisions; and

3) through judicial review. In addition, NFMA

instructs the agency to coordinate its planning

process with those of other Federal agencies and

State, tribal, and local governments. Taken together,

these charnels for public participation are intended

to expand and elevate the public’s historic role in

Forest Service decisionmaking and to assure that

public values, needs, and desires are reflected in

forest plans.

This chapter will ex amine public involvement in

forest planning at the stages referred to above. The

first part examines public participation at the plan

development and implementation stage. Specifically, it discusses the legal framework for public

participation and Forest Service efforts to integrate

the public in its decisionmaking. It also addresses

why those efforts seem inadequate, and reviews

alternative approaches to public involvement in

Forest Service decisionmaking. The second part

discusses the role that administrative appeals play in

the planning process, and analyzes current issues

and concerns surrounding the use of the appeals

system. It also discusses the role of the judiciary in

forest planning, and specifically addresses issues of

judicial review. Finally, the third part of the chapter

examines the additional requirements for coordinating Forest Service planning with other government

activities.

PUBLIC PARTICIPATION IN

FOREST SERVICE PLANNING

Legal Requirements

Forest Service land and resource planning and

management is guided primarily by three laws: the

Multiple-Use Sustained-Yield Act of 1960 (MUSYA),

NEPA, and NFMA. (See ch. 4 for a more thorough

discussion of the legal framework for Forest Service

planning and management.) Taken together, these

statutes provide both a conceptual basis and a firm

legal mandate for public involvement in the forest

planning process. Common among these laws is the

implicit recognition that planning and managing

public resources is not solely a function of technical

expertise and scientific decisionmaking. It is inherently a subjective process, dominated by social,

political, and cultural questions (49, 51, 330). (See

also ch. 3.) The Forest Service must involve the

interested publics in a meaningful way, if the

resulting plans are to respond to changing public

needs and values (3, 49, 51, 231, 330).

-77–
78 ● Forest Service Planning: Accommodating Uses, Producing Outputs, and Sustaining Ecosystems

The Multiple-Use Sustained-Yield Act of 1960

The passage of MUSYA in 1960 and several

Federal statutes in the 1970s significantly opened up

administrative agency procedures to closer public

scrutiny and more active public involvement. Under

MUSYA, the Forest Service retained primary authority and significant discretion over the management of the forest resources. Nevertheless, by

expanding the number of public resources over

which the agency had express management and

regulatory authority, the act provided a stronger

conceptual basis for agency responsiveness to pluralistic, public values than had previously existed.

MUSYA directs that, in managing the national

forests, the Forest Service shall give “due consideration . . . to the relative values of the various

resources, and shall assure that resources are

‘‘utilized in the combination that will best meet the

needs of the American people. ” As discussed in

chapter 3, the act embraced the concept that the

public’s interest is best served by managing the

national forests for many values. However, the act

provided only the most general guidance to agency

managers as to how to do this. (See ch. 4.)

MUSYA provided a theoretical framework for

public participation by focusing agency attention on

multiple resource management. This mandate

placed the agency in a more visible position of

weighing and balancing resource values and uses

and of reconciling conflicts. And because planning

and management decisions were supposed to be

guided by the ‘‘needs of the American people, ’

MUSYA began a trend toward external, as opposed

to bureaucratic, standards of accountability (231).

However, it did not provide the general public with

any legal right to participate in forest planning.

The National Environmental Policy Act of 1969

Throughout its history, the Forest Service had

solicited public input into its decisionmaking processes, but often informally and infrequently (208).

With the enactment of NEPA in 1970, the agency

was expressly required to establish procedures for

public involvement in planning and management.

Congress enacted NEPA at a time when the public

was demanding more access to administrative decisionmaking. NEPA requires Federal agencies to

assess the environmental effects of any proposed

major Federal action that would significantly affect

the human environment. NEPA emphasizes “full

disclosure’ of agency decisions—findings from

environmental assessments and impact statements.

An examination of alternatives to the proposed

action, and comments from reviewing State and

Federal agencies, must also be made available to the

public.

NEPA does not provide standards and guidelines

for public involvement, nor does it specify that

public meetings must be convened. It treats the

public principally as a recipient of information,

rather than a participant in decisionmaking (231).

Under the law as written, Federal agencies have a

duty to make environmental impact statements

available for review, but are not required to solicit

feedback from the public.

Nonetheless, public awareness of potential environmental consequences of proposed programs or

actions makes agencies more accountable to public

concerns and more sensitive to the environment

(231). President Richard Nixon made it clear that

Federal agencies were to actively seek public views

before making final decisions. His Executive order

to implement NEPA directed agencies to:

Develop procedures to ensure the fullest practicable provision of timely public information and

understanding of Federal plans and programs with

environmental impact in order to obtain the views of

interested parties. These procedures shall include,

whenever appropriate, provision for public hearings,

and shall provide the public with relevant information, including information on alternative courses of

action (183) (emphasis added).

President Nixon had instructed the Council on

Environmental Quality (CEQ) to issue guidelines to

Federal agencies for preparing Environmental Impact Statements rather than regulations. Regulations

to implement NEPA were subsequently issued under

President Carter in 1978. These regulations provide

clearer guidance to agencies on the purpose of public

involvement, and give the public a more participatory, consultative role than the vague “inform and

educate’ language of the law had done. The

regulations provide that:

Federal agencies shall to the fullest extent possible. . . [encourage and facilitate public involvement

in decisions which affect the quality of the human

environment (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 hearings, public meetings, and the availability of environmental documents . . .

(c) Hold or sponsor public hearings or public

meetings whenever appropriate . . .

(d) Solicit appropriate information from the public

. . .

(e) Explain . . . where interested persons can get

information or status reports on environmental

impact statements . . . and

(f) Make environmental impact statements, the

comments received, and any underlying documents

available to the public . . .

under the regulations, agencies are thus responsible

for involving the public in decisions affecting the

human environment.

NEPA regulations also direct a process to facilitate decisionmaking, not to justify predetermined

decisions. “NEPA procedures must insure that

environmental information is available to public

officials and citizens before decisions are made and

before actions are taken” (40 CFR 1500. l(b))

(emphasis added). The regulations also require that

agencies solicit public input early in planning and

decisionmaking through ‘‘ scoping’ ‘—’ ‘an early and

open process for determining the scope of issues to

be addressed and for identifying the significant

issues related to a proposed action’ (40 CFR

1501 .7). Furthermore, NEPA regulations direct agencies to ‘ ‘integrate the NEPA process with other

planning at the earliest possible time to insure that

planning and decisions reflect environmental values,

to avoid delays later in the process, and to head off

potential conflicts” (40 CFR 1501.2).

While the regulations set forth clearer guidance to

agencies on why to involve the public in planning

and decisionmaking, standards for public participation in forest planning are evolving largely through

case law. (See ch. 4.) Courts have provided some

guidance as to NEPA’s public participation requirements. In California v. Block,l the court noted that:

1) the Forest Service was required to present a broad

range of alternatives to allow full public participation in decisionmaking, and 2) information from the

public was not only to be collected, but was also to

be considered in decisionmaking (92). Nonetheless,

two important questions regarding public participation in forest planning under NEPA remain largely

unanswered:

1. What is the role of the public (vis-a-vis agency

responsibility) in Forest Service decisionmaking?

2. How must the Forest Service demonstrate its

response to public comments in its final forest

plans and decisions?

The National Forest Management Act of 1976

With the passage of NFMA in 1976, Congress

reinforced the public’s right to participate in Forest

Service planning and decisionmaking. Enactment of

the law was largely triggered by the Monongahela

decision2 and other court decisions that threatened to

halt certain timber harvesting practices in the

national forests. (See ch. 3.) However, the controversy in the Monongahela National Forest of West

Virginia was not unique, but rather an indication of

widespread public dissatisfaction with Forest Service Management practices (80). Lawsuits were filed

in Alaska, Texas, and several other States. Disputes

about management of the Bitterroot National Forest

in Montana led Congress to commission an independent evaluation of Forest Service practices (264).

The Monongahela and Bitterroot controversies

involved not only the legitimacy of timber management practices under the 1897 Forest Service

Organic Act, but also questioned the agency’s

interpretation of its multiple-use and sustained-yield

mandates. The uproar over clearcutting was ‘‘but the

focal point for groups with a broad range of interests

in reforming national forest management’ (80).

These conflicts demonstrated public perceptions of

the agency as insensitive to nontimber values, and

public demands for greater agency accountability in

upholding its multiple-use mandate.

NFMA embraces the notion set forth in the NEPA

regulations—that many conflicts can be reconciled

by integrating the public into the decisionmaking

process early and continuously. Upon submitting the

conference report on NFMA to the Senate, Hubert

Humphrey, the chief sponsor of the bill, characterized the public as ‘‘advisers’ to agency planners and

decisionmakers:

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).
80 ● Forest Service Planning: Accommodating Uses, Producing Outputs, and Sustaining Ecosystems

This is an act that assures that our public forests

are managed with advice from the several publics,

and managed in a framework that makes ecological

and environmental sense . . .

It creates the policy machinery for making certain

that professional expertise and public desires are

brought together in the public interest (120).

President Gerald Ford echoed the Senator’s remarks:

“Emphasis throughout the act is on a balanced

consideration of all resources in the land management process. Of equal importance, this act guarantees the full opportunity to participate in National

Forest land and resource planning” (87).

NFMA directs the Secretary of Agriculture to

promulgate regulations specifying procedures to

ensure that forest plans are developed in accordance

with NEPA, although such regulations have never

been promulgated. The conference report on NFMA

emphasized that the purpose of this provision was

not to amend or mod@ NEPA, but to assure

“uniform guidance . . . as to what constitutes a

major Federal action for which an environmental

impact statement is required” (266).

In addition, rather than just referring to NEPA for

guidance on public participation, section 6(d) of

NFMA specifically requires public participation ‘in

the development, review, and revision” of forest

plans. This provision directs the Secretary at least to

make the documents available at convenient locations and to “hold public meetings or comparable

processes . . . that foster public participation in the

review of such plans or revisions. ’ Furthermore,

Congress conferred an additional opportunity for the

public to influence the regulations implementing

NFMA in section 6(h), by providing for advice and

counsel from an independent committee of scientists

“to assure that an effective interdisciplinary approach is proposed and adopted. ”

Finally, section 14 authorizes and encourages the

use of advisory boards in planning and managing the

national forests. Section 14(b) specifies:

In providing for public participation in the planning for and management of the National Forest

System, the Secretary. . . shall establish and consult

such advisory boards as he deems necessary to

secure full information and advice on the execution

of his responsibilities. The membership of such

boards shall be representative of a cross section of

groups interested in the planning for and management of the National Forests System and the various

types of use and enjoyment of the lands thereof.

Despite such direction, the Forest Service has not

used any formally designated advisory boards for

national forest planning or management since the

late 1970s. In one case, the White Mountain

National Forest in New Hampshire, an existing

advisory board that was officially disbanded in the

late 1970s has continued meeting without explicit

Forest Service coordination and assistance as an Ad

Hoc Advisory Committee. The Forest Service has

stated that the requirement to conform with the

Federal Advisory Committee Act (FACA) inhibits

their use of advisory boards, but how and why

FACA inhibits advisory board use has not been

explained or demonstrated.

Taken together, these several sections of NFMA

project the public as an integral component of forest

planning and implementation. While the law preserves agency decisionmaking authority, it casts the

public in the role of advisers and consultants to the

planning and decisionmaking processes.

NFMA Regulations

In the fall of 1979, the Secretary of Agriculture

promulgated regulations to govern the implementation of NFMA. These regulations provide substantial guidance on public participation, and furthered

Congress’ intent that public involvement should

constitute more than a mere exchange of information. Section 219.7(a) sets forth the intent of public

participation to:

(1) ensure that the Forest Service understands the

needs and concerns of the public;

(2) inform the public of Forest Service land and

resource planning activities;

(3) provide the public with an understanding of

Forest Service programs and proposed actions;

(4) broaden the information base upon which land

and resource management planning decisions are

made; and

(5) demonstrate that public issues and inputs are

considered and evaluated in reaching planning decisions.

Section 219.7(e) provides further that “conclusions

about [public] comments will be used to the extent

practicable in decisions that are made. ” This constitutes the first time that the agency was explicitly

required to reflect public input in forest management

plans and decisions.
—. . . .—... . —.

Chapter 5--Public Involvement in Forest Planning ● 81

The regulations provide reasonably clear guidance to agency managers on the purposes and

objectives of public involvement, but also provide

the agency with significant discretion in choosing

the best methods for public participation. Section

219.7(c) states, “Public participation, as deemed

appropriate by the responsible official, will be used

early and often throughout the development, revision, and significant amendment of the plans

(emphasis added). Nonetheless, the Forest Service

must demonstrate that it has considered public input

in reaching its final decisions. Thus, section 219.7(a)(5)

was of special significance, because it forced action

in response to public comments-the agency was

specifically required to be “responsive” to public

participation.

The NFMA regulations were significantly

changed in 1982, as part of the sweeping changes

recommended by President Ronald Reagan’s Task

Force on Regulatory Reform. The Task Force

recommended that much of section 219.7 be eliminated or changed (269). Section 2 19.7(a) would have

been reduced to a single, broad statement of purpose:

‘‘public participation throughout the planning process is encouraged. ” Because of strong public

criticism, however, the Forest Service retained most

of the original language (92). Nonetheless, the

sections that most strongly required Forest Service

responsiveness to the public—section 219.7(a)(5) to

demonstrate consideration of public issues and

inputs, and section 219.7(e) to use conclusions about

public comments to the extent practicable-were

deleted.

The Forest Service has defended the deletion,

arguing that the sections were unnecessary, inaccurate, and nonregulatory, and thus inappropriate for

NFMA regulations (92). However, several observers

have criticized the Forest Service for eliminating

those particular provisions which most clearly

forced the agency to respond to public comment.

These 1982 changes have significantly increased

agency discretion of how to use public comments

and have contributed to ‘‘erosion of the role of the

public as participant in the planning and decision

process . . .“ (emphasis in original) (231).

Forest Service Efforts in Public Participation

It is widely held—by Members of Congress,

members of the general public, academicians, and

many agency personnel-that the Forest Service has

not efficiently or effectively used public input in its

planning process (27, 91,231, 277,281, 330). This

inefficiency is manifested, in part, by the rising

number of appeals and lawsuits over forest plans and

proposed activities. It is important to note that the

issue surrounding public participation is not solely

a question of whether the Forest Service has

technically complied with the letter of the law, but

also whether the agency has fulfilled the spirit and

intent of the laws.

The Forest Service acknowledges that public

participation is an important objective of its planning process, and provides numerous opportunities

for the public to participate throughout the planning

process. Nevertheless, the Forest Service has not

demonstrated much success in achieving effective

public participation; few forest plans show the

degree to which public concerns have been accommodated or how managers have considered and

responded to public issues and concerns. Some

national forests have succeeded at involving the

public in planning and decisionmaking, but for the

most part, forest supervisors apparently lack sufficient training, guidance, and flexibility to respond

adequately to public input.

Integrating the public into forest planning, implementation, and monitoring is admittedly difficult.

The Forest Service is required to solicit public

involvement in at least ten distinct points in the

planning process (330). In addition, a large number

of specific decisions affect the ‘‘public interest, ’

and this number has grown enormously since the

passage of the MUSYA in 1960. Furthermore,

agency leaders, observers, and participants differ on

the public’s role in planning and decisionmaking.

NEPA and NFMA both contemplate that public

concerns and issues will be reflected in the planning

process, but neither specifies how and to what extent

plans and decisions should accommodate these

concerns. Because the Forest Service has not clearly

defined the role of the public in the planning process,

both agency managers and the public have different

expectations and perceptions of the extent to which

public input should influence final decisions.

Historical Development

Forest Service planning and management have

been increasingly attacked since the 1960s. Because

of the wide discretion of the Forest Service to make

and implement forest policy, several interest groups

felt that their views were systematically underrepre-
82 ● Forest Service Planning: Accommodating Uses, Producing Outputs, and Sustaining Ecosystems

sented in plans and decisions (330). Though seldom

faulting the professionalism of the agency’s work

force per se, some critics have charged that the

agency simply has been inclined toward certain

interests, while others have asserted that the agency

was ‘captured’ by outside interests (202,250, 330).

The Bitterroot and Monongahela debates demonstrated the controversial and political nature of

public land and resource management and highlighted the public’s growing expectation for a

greater role in Forest Service decisionmakin g. The

perceived lack of responsiveness to public needs and

values led to calls for agency reform. In 1970, the

Belle Report concluded in part that “the staff of the

Bitterroot National Forest finds itself unable to

change its course, to give anything but token

recognition to related values, or to involve most of

the local public in any way but as antagonists” and

recommended agency reorganization so that public

involvement would “naturally take place” (264).

The 1971 Forest Service policy statement on public

participation was not followed in practice (29). In

1972, Cutler recommended five reforms aimed at

improving agency responsiveness to public concerns: 1) active recruitment of diverse professionals

for a‘ ‘multidisciplinary’ staff; 2) early involvement

of all interests in decisionmaking; 3) use of ‘ ‘independent hearing officers and semi-independent citizens’ committees’ to review plans and decisions; 4)

more and broader alternatives for public review and

comment; and 5) adequate time to review alternatives (330)0

Current Conditions and Trends

Criticism of Forest Service decisionmaking has

hardly fallen on deaf ears. Since 1970, the agency

has adopted scores of procedural reforms aimed at

promoting public involvement in its policymaking

processes. NEPA documents are widely distributed,

public meetings are now commonplace, alternatives

are routinely reviewed by interested publics, and the

agency has used a growing number of citizen

working groups to avoid plan appeals.

Despite Forest Service reforms, public dissatisfaction with final plans and decisions remains high,

indicating that many still believe that the agency is

unreceptive and unresponsive to their concerns and

priorities. A recent survey of forest planning participants shows 43 percent were “somewhat to very

dissatisfied” with the planning process in which

they had participated, and 55 percent voiced frustration with the Forest Service planning process as a

whole (68). In addition, 72 percent believed that the

Forest Service unfairly favored some interests over

others when preparing forest plans (68).

The Forest Service undertook its own internal

review of the planning process under NFMA. Most

of the employees surveyed indicated that the agency

had technically complied with public participation

requirements contained in the law and the regulations. However, the public was seen as dissatisfied

with Forest Service attempts to involve them. Only

3 percent of the employees believed that public

participation had affected final forest plans (279).

A 1990 report, which solicited comments and

ideas about the forest planning process from a host

of persons representing various interests, academia,

State and local governments, and the general public,

likewise reported a widely held feeling that Forest

Service officials ‘do not welcome proactive participation . . . but prefer to accept information only on

their own terms and in forums organized by the

Forest Service” (277). The participants felt that the

agency’s public hearings, arranged to invite views

on issues, forced groups into taking hard, polarized

positions at the outset. ‘‘The planners then retreated

to their offices, emerging sometime later with a

draft, followed by another public hearing-and

increased polarization” (277). The report attributed

part of the problem to the lack of a clear agreement

and understanding within the agency on the role of

the public in reaching decisions (277).

While acknowledging shortcomings in public

involvement, other observers maintain that the

Forest Service has been relatively successful in

promoting public participation, given the extensive

and complex requirements of NEPA and NFMA. As

the planning process continues to evolve and mature,

public participation efforts will likely improve,

assuming that agency leadership acknowledges the

importance of public participation and actively

encourages and is receptive to public input. In

October 1989, Forest Service Chief Dale Robertson

(207) stated, “In preparing these forest plans, we

have worked with the public. We have come down

on what we believe is the best balance after taking all

the factors into account. ” The 1990 internal critique

of land management planning echoed the Chief’s

remarks:

Great strides have been made in Forest Service

planning. Citizens were involved to an unprece-
Chapter 5--Public Involvement in Forest Planning ● 83

dented extent. . . Many important relationships, with

citizens, local officials, other agencies, and Indian

tribes, have been formed . . . There was frustration,

but there is a general feeling that individuals inside

and outside the agency did the very best they knew

how . . . [P]ublic participation methods changed as

the planning process matured and as results indicated

the need for changes. Such change will continue as

we enter the next phase of forest planning (276)

(emphasis in original).

Many questions concerning the legal adequacy of

public involvement methods have been resolved

through the administrative appeals process (155).

According to the Forest Service, appeals have

played an important role in “testing the soundness

of the agency’s day-to-day decisions, current policy

and use of discretion. Thus, appeals can and do help

refine and clarify Forest Service policies and procedures” (155). The agency’s critique, which includes

a series of recommendations designed to promote

greater responsiveness to public input, is further

evidence that the agency is learning from its

experiences and attempting to improve public participation. This critique also prompted the agency to

update its training course on plan development and

implementation to ensure that needed changes are

communicated to staff in the field.

Public participation probably will continue to

improve as the agency becomes more experienced

with the NEPA and NFMA processes. Nonetheless,

there still appears to be a substantial gap between

stated policy and the actual practice. Much of the

criticism heard today echoes of that heard more than

20 years ago-that although the agency solicits

public input, few participants perceive that their

input has a noticeable impact on plans or decisions.

The failure of Forest Service efforts to meet public

expectations about being included in decisionmaking is common to Federal agencies (4). The promise

of citizen participation in policy formulation and

decisionmaking is seldom fulfilled, because for the

most part, effective techniques of involvement and

participation have not been widely adopted (231).

Reasons for Difficulties

Critics who charge that changes in the Forest

Service’s public involvement strategy and approach

have been minimal, question the extent to which the

agency has learned from past experiences (92, 230,

231, 330). The most common explanations for

Forest Service difficulties in effectively involving

the public in planning and decisionmaking are the

use of incorrect models of public involvement, the

lack of information on how to involve the public,

professional resistance to public ideas, and inflexible conditions for managers.

incorrect Models--One explanation for why the

Forest Service has failed to meet public expectations

for participation is that the agency has not developed

an appropriate model for encouraging and using

public input. Likewise, the Forest Service managers

have been unable to provide the public with a clear

understanding of the purpose of their involvement or

how their input would be used. “People did not

know the level of specificity they were expected to

make in their comments because they did not

understand the decisions that were going to be

made” (277).

Typically, the Forest Service convenes a meeting

of various individuals and interests to discuss a set

of issues determined by the Forest Service (277).

This ‘has led to issue-airing and venting, but has not

affected decision-making” (277). By asking for

interests and preferences, the agency encourages the

public to act individually and separately (231). This

approach suggests that the agency views the public

narrowly, as a “gaggle of consumers,” i.e. as

individuals and groups with predetermined and

static values and preferences (231).

This “model” of public participation is premised

on the assumption that due process is the appropriate

means to guarantee public access to agency planning

and decisionmaking (231). The publics are given

sufficient opportunities to present their views, and

all views are considered, but the agency is the sole

decisionmaker and final arbiter. The publics are thus

placed 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 behavior

and inhibits the ability of affected groups and

individuals to find mutually acceptable alternatives

(330). Citizens have no collaborative forum in which

to learn about one another, to revise their opinions,

or to discover common interests and mutually

beneficial solutions (23 1, 330). Rather than promoting a dialogue among the agency and the publics,

current models and approaches reduce the purpose

of public input to mere information gathering;

communication typically flows only one way—from

the public to the agency (92, 231, 277, 330). The
84 ● Forest Service Planning: Accommodating Uses, Producing Outputs, and Sustaining Ecosystems

process neither convinces nor informs the public,

because it “does not provide the opportunity for

mutual inquiry to better understand the issues

involved and the merit of a variety of different

alternatives; . . . affected groups are not given the

opportunity to amend, support, or reject their early

notions’ (330). Thus, many are not convinced that

final decisions are the most acceptable ones that

could have been reached.

The adversarial model of public participation also

promotes distrust of the agency, because those who

disagree with the decisions tend to view agency

managers as the agents of the opposing interests

(330). Furthermore, the public strongly perceives

that forest planning has been used to justify predetermined decisions (277). Decisions disappoint many

participants, because they have not been convinced

by the decisionmaking process “that the decision

reached is right’ (330). Participants ‘wanted a clear

and credible rationale for the decision that showed

that their comments had been heard, understood and

considered, and evidence that the Forest Service had

acted on the best information available” (277). All

too often this rationale has not been forthcoming in

final plans and written decisions.

For want of a clear understanding of the role of the

public, managers tend to measure the adequacy of

public involvement practices in terms of simple

process or interest representation (231)--how many

public hearings were held; how many different

interest groups were present at these meetings; how

many comments were collected; etc. Because agency

officials lack explicit formulas for decisionmaking,

they seek to compensate by being “systematic and

thorough” in their approach to public involvement

(330). This ensures that virtually every affected or

interested group and individual has an opportunity to

present their views, but provides no guidance to

managers on how to integrate the public into the

process of weighing alternatives, evaluating tradeoffs, and making final decisions. This approach fails

to distinguish between ‘‘interest airing’ and ‘‘interest accommodation ’’-concepts with significantly

different implications (330). The current Forest

Service approach tends to be based on interest airing

alone, and is not designed “to accommodate [the

publics’] concerns in a way that satisfies them that

they have indeed been accommodated as well as

possible” (330). “Issue airing,” without involvement in the decisionmaking, encourages participants

to argue positions rather than to discuss the larger

interests and issues at stake (83).

Insufficient Data—Some observers attribute the

agency’s failure to engage the public in the planning

process to the lack of data available on the most

effective and efficient public participation techniques and methods. “Little empirical research is

available to help forest managers understand public

participation . . . [and] empirical data in social

science literature that analyze the most appropriate

methods to involve the public in resource decisionmaking are scarce’ (86). A survey of forest planning

participants in Idaho and Washington identified five

participation methods preferred by the public: 1)

citizen representatives on Forest Service policymaking bodies, 2) formal public hearings, 3) surveys of

citizen attitudes and opinions, 4) open public meetings, and 5) meetings held for residents of specific

communities (325). However, none of these five

methods were used by any of the national forests in

the survey area (325). Arguably, information on

public preferences could assist managers in stimulating better local public participation.

The Forest Service also lacks empirical evidence

on the people who tend to participate in forest

planning (86). No research has identified or examined demographic, sociological, or other characteristics of the people who participate. It is difficult to

design effective involvement programs without

understanding the characteristics and interests of the

participants. ‘‘Empirically derived information can

help forest managers understand the public more

accurately and can help participation officers design

programs for the population in general and for

specific groups” (86).

Resistance to Public Involvement—The mandate

for more extensive public participation in the forest

planning process was imposed upon an agency that

had traditionally operated relatively autonomously.

While agency leaders were receptive to the charge

for greater public involvement, both NEPA and

NFMA required major changes in the reamer in

which the agency operated. Field managers were not

experienced or trained in integrating the public into

the decisionmaking process, and little guidance was

provided on how and why to accommodate the

public; consequently, public participation methods

have evolved slowly.

Numerous critics assert that the agency leadership

does not welcome proactive participation, because it
Chapter 5-Public Involvement in Forest Planning . 85

can be counterproductive-sometimes the public

wants decisions that are inappropriate, infeasible, or

inconsistent with agency policies (92, 159,229,231,

277). Forest supervisors often believe that ‘proper’

decisions must be internally consistent (“loyalty to

the party line’ ‘); responding to local interests is thus

irresponsible, unless the decision is unequivocally

faithful to agency policies and decisions (229, 231).

Consequently, the agency has preferred to accept

public input only on its terms and in forums it has

organized (277).

Another allegation is that the Forest Service

resists meaningful public participation to preserve

its decisionmaking autonomy and discretion. Being

responsive to the public may restrict certain agency

activities or options. Forest Service employees have

been described as reluctant public servants, who

“still seem to regard their work as the strict

application of natural science to the management

and protection of the environment’ (159). Professional resource managers believe that their training

and experience equips them to make decisions and

that, by and large, the public is uninformed and too

diversely opinionated for useful input and sound

decisionmaking (227).

Natural resource personnel surveyed from several

agencies felt that the public, even the interest groups,

had little knowledge of land and resource management issues (237). Thus, managers work to ‘ ‘educate’ the public and change people’s minds about

the agency policies and practices rather than explore

alternatives to satisfy the public’s goals and objectives. “Information programs are undertaken more

from a desire to shape public opinion than to

incorporate public opinion into policy decisions’

(159). The Forest Service typically develops and

defines public issues internally and then invites the

public to review and comment (77). This approach

perpetuates the notion that public participation is

nothing more than a forum in which to ‘‘inform and

educate’ the public.

This attitude impedes listening to the public. The

Forest Service employs many professionals, with

diverse backgrounds. However, resource expertise is

also employed by State agencies, by other Federal

agencies, by universities and consultants, and by

many interest groups. Even the uninformed can have

intelligent ideas about land and resource management. Sometimes the most innovative suggestions

come from those whose thinking has not been

narrowed by professional training. Furthermore,

education is most likely to occur, not when the

public is told what is feasible, but when it is guided

to reach its own conclusions. Finally, professionals

often do not realize that their technical decisions

may intrude on public values, and only public

participation can define which decisions are technical and which are public (3).

The emphasis on retaining autonomy and discretion has prevented the agency from using effective

models of participation in forest planning and from

resolving basic issues such as the identity of the

publics, the roles of the agency and the public in the

planning process, and the degree of influence the

public should exercise over final decisions (231).

The unwillingness to allow the public to play a

greater role in planning and decisionmaking has

stifled the agency’s capacity to learn-to carefully

evaluate and reflect on past programs and policy

commitments, to examine a wider range of alternatives to proposed actions, and to respond to changing

public values and priorities (203, 231).

Inflexible Conditions—The 1970 Belle Report

found that Forest Service managers in the field

lacked the flexibility needed to respond effectively

to public needs:

In order to maximize local community support

those persons in the Forest Service most intimately

associated with local community interests [i.e., the

district rangers] must be free to act . . . yet his [sic]

authority is severely limited and all too frequently

his decisions and answers are bureaucratically determined . . , He is therefore denied the flexibility to

meet issues and problems on an ad hoc basis. It might

also be said that his decisions are always predetermined, at least with respect to major issues and

problems (244).

Furthermore, the Forest Service does not reward

managers or other employees for accommodating

the public:

Unless there is freedom to solve resource related

problems on a situational basis, there are no grounds

for public participation . . .[but] public participation

is the key in determining the particular expression of

public interest to particular problems (29).

Evidence suggests that the inflexibility described

in the Belle Report 20 years ago remains. Forest

supervisors and district rangers are often constrained

from responding to public issues by a host of factors

beyond their control. For example, allocated na-
86 ● Forest Service Planning: Accommodating Uses, Producing Outputs, and Sustaining Ecosystems

tional goals and objectives, set in the RPA Program

and through annual budgets, frequently contradict

those derived at the local level, effectively preempting forest plans. Control systems-rewards, incentives, and budgets—are not linked to the plans.

Local forums designed to encourage deliberation

and debate among the most interested publics are for

naught, if they are systematically overruled by

national policies that are insensitive to local concerns.

Even agency employees note that local planning

and response to local publics are being overridden.

In an open letter to the Forest Service Chief, forest

supervisors from the Rocky Mountain areas stated:

The emphasis of National Forest programs does

not reflect the land stewardship values embodied in

forest plans, nor does it reflect the values of many

Forest Service employees and the public. , . Program/

budget testimony is constrained by Administration

objectives. Program shifts contained in forest plans

and public opinion are not expressed . . . in annual

budgets and agency policies (90).

In their recent recommendations to the Chief, these

forest supervisors echoed the conclusions of the

Belle Report:

Field line officers should become more effective

in working with local, State and National key publics

and elected leaders to build support for Forest

Service programs generally, and to discourage specific earmarking (90).

Finally, the functional organization of the Forest

Service employees and resource-oriented budgets

impair a manager’s ability to implement integrated

resource plans. Many interests and employees believe that functionalism has led to funding for some

resources and not for others (276, 277). It is argued

that the differences between funding called for in the

plans and actual appropriations prevent the agency

from meeting the intent of NFMA, because the truly

interdisciplinary and integrated plans cannot be

implemented as planned (149).

Reducing Conflict Through

Cooperation and Collaboration

The preceding discussion of problems in involving the public is not to suggest that agency efforts at

public participation have been a total failure on

every national forest. Despite the lack of agreedupon criteria to evaluate the success or effectiveness

of public involvement, observers cite a number of

forests that have achieved “viable plans” (330).

Typically, these forests brought diverse groups

together to identify issues and discuss alternatives;

these informal citizen working groups and forums

encouraged debate, dialogue, and deliberation among

the groups and with the agency. According to several

observers, success largely depended on the initiative

of particular forest supervisors (or in some cases

regional foresters), rather than on guidance from

agency leadership (229, 231).

Typically, where a forest plan was deemed a

success, there was a forest supervisor who understood the social and political environment, was able

to read the forest constituency well, and personally

navigated the plan through the reefs of public

controversy (277).

Other forests seem to have committed themselves

to meaningful participation in their final forest plans.

For example, in the Ochoco National Forest:

Incorporation of public involvement into decisions being reached in the final Forest and Grasslands Plans has been an integral step in progressing

from the draft documents . . . Significant steps were

taken during the last four months of final document

preparation to insure that direction in the final plans

responded accurately to comments received on the

draft. In response to public comment, new information and legislation, significant changes were made

in the preferred alternative between Draft and Final.

Concurrently, with the alternative modification, the

Forest Service worked closely with the public in

attempting to validate and/or seek ‘consent’ for the

Final Plan (274).

Although this statement alone does not prove that

public participation was effective on the Ochoco, it

does indicate that the agency recognizes the importance of public participation in the planning process,

and acknowledges that public input should be

reflected in final plans and decisions.

These successes and commitments are a valuable

beginning to effective involvement of the public in

forest planning and decisionmaking. However, if

public participation in forest planning is to fulfill the

purposes of NEPA and NFMA, the Forest Service

must provide consistent and organized direction for

improving public participation. Effective participation is not solely a function of process and procedures; managers must have a clear idea of why the

public is being consulted for particular decisions,

and how they should consider and respond to public

input.
—.- —

Chapter S-Public Involvement in Forest Planning ● 87

Why Involve the Public in Forest Planning

The decisionmaking responsibilities of Federal

administrative agencies, including the Forest Service, contain duties best described as ‘‘quasilegislative’ in nature. This is true whenever Congress vests substantial discretion in an agency to

execute broad or general legislation, such as MUSYA.

Reich (203) noted the ‘practical necessity’ of broad

administrative discretion, due to the growth in the

administrative state in the last 50 to 60 years.

However, broad grants of administrative discretion

can also be inconsistent with a ‘‘pluralist vision of

society, because broad discretion creates “the

possibility that unelected bureaucrats could impose

their own ideas on the public” (203). Concern over

the legitimate role of the public administrator led to

the creation of the administrative process; “Administrators, in theory, became managers of neutral

processes designed to discover optimal public policies” (203).

Agency planning activities have been characterized as falling somewhere between rulemaking and

adjudication. Planning activities prior to NFMA,

however, were generally considered exempt from

the requirements to involve the public under the

Administrative Procedures Act (APA) (208), and

NFMA did not directly alter this situation. The

Forest Service’s broad mandate in MUSYA necessarily requires agency managers to allocate scarce

public resources, and NFMA preserves broad agency

discretion in planning. Thus, the concerns about

representation and agency accountability to the

public have grown steadily. For example, the

Bitterroot and Monongahela controversies erupted,

in part, because some members of the public

believed that Forest Service policies were unresponsive to and inconsistent with public demands.

Increasingly over the past two decades, the public

has demanded and expected the right to participate

in Forest Service planning and decisionmaking.

Given the nature of Forest Service responsibilities

—allocating scarce public resources through longrange, integrated resource planning and management—the call for greater public representation and

involvement in agency decisions seems perfectly

logical (202). While a strictly democratic approach

to agency decisionmaking might be too cumbersome

and costly, only public participation can assure that

the allocation of forest resources best satisfies the

‘ ‘public’s interest.’ In 1962, Reich wrote:

. . . [it] can be argued that in a democracy the ‘public

interest” has no objective meaning except insofar as

the people have defined it; the question cannot be

what is “best” for the people, but what the people,

adequately informed, decide they want.

Failure to involve interested publics in planning

can lead those publics to choose other forums-such

as Congress and the courts-to press their demands,

and may result in final plans that cannot be

implemented (49, 203, 231).

Affected and interested individuals and groups

can contribute to agency decisionmaking processes

in several ways. Public involvement is most commonly viewed as a means to provide agencies with

greater insight into values, needs, and priorities than

would be available without such input. Perhaps more

importantly, however, public participation can serve

to define the important decisions and relevant

information for decisionmaking (92). Public involvement can lead agency managers to consider a

wider range of issues and to articulate concerns more

clearly (92, 203, 330).

Public participation can also serve as an “early

distant warning system, ” alerting agency planners

and managers to resource issues that are likely to

cause significant controversy in the future. With

more direct insight into public values and priorities,

the agency can develop plans that address new and

emerging concerns and, in theory, avoid making

decisions that prompt appeals and litigation and that

delay implementation (49, 306). If used effectively,

public input can help agency managers detect and

address problems early, thereby leading to more

efficient and expeditious implementation of the

plans on the ground.

Finally, public participation can also improve

agency accountability. Several observers argue that

public involvement is needed as a representative

check on agency activities (92, 203):

Administrative agencies . . . have been making

decisions in a temporary political vacuum. Thus, in

a sense, the present day participatory emphasis

represents a restoration of the political balance in our

democracy-a balance that was temporarily lost

because the complexity of problems developed

faster than the institutional capacity to deal with

them through representative procedure (186).

Including the public in the decisionmaking processes helps to ensure that agencies accurately

determin e the ‘‘public interest’ in a given situation
88 ● Forest Service Planning: Accommodating Uses, Producing Outputs, and Sustaining Ecosystems

and respond appropriately; public participation can

help to bridge the gap between actual public values

and those perceived by the agency.

The Forest Service has a distinguished history of

managing the public forests and rangelands. The

agency’s professionals have traditionally been educated in a variety of professional and scientific

disciplines and have historically maintained virtually exclusive decisionmaking authority over the

allocation and management of national forest resources (202, 208, 324). However, as noted in

chapter 3, conflicts over resource use have intensified since the 1950s and the agency’s statutory

mandate has been broadened to include express

consideration of more noncommodity values. Consequently, the number of subjective, value-laden

questions confronting managers has increased significantly, limiting the ability of professionals to

determine and represent the “public interest” (202,

330).

“Goodness” and “badness” in our society are

collective value judgments, and land expertise is no

better qualification than many others for making

them (15).

While education, training, and open-mindedness are

important characteristics of land and resource professionals, these characteristics do not give managers any special ability or authority to represent the

values of others (15, 202, 330). To the extent

interested members of the public are allowed to

represent their own concerns and values, public

participation can inform and guide final plans and

decisions (330).

This is not to suggest that all battles over forest

management can be avoided by involving the public

in planning and decisionmaking; mutually satisfactory decisions simply cannot be reached on some

issues (203, 330). Also, the agency should not be

relieved of management authority and responsibility.

[T]he issue is not whether the public or experts are

to manage, but whether, and to what degree, the

experts should be made aware of, and responsive to,

public opinion (202).

Forest Service managers are, ultimately, responsible

for making decisions. Nonetheless, public involvement can help managers: 1) determine important

public values and priorities, 2) define critical issues

and 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 promote

public participation are frequently flawed, because

public wants are often assumed to be predetermined

and static. The primary purpose of public participation, therefore, is presumed to be gathering from the

public.

People’s preferences are assumed to exist apart

from any process designed to discover and respond

to them, that is, outside any social or political

experience in defining the nature of the problem and

attempting to resolve it. . . Individual preferences do

not arise outside and apart from their social context,

but are influenced by both the process and the

substance of public policy making (203).

Public participation in Forest Service decisionmaking is valuable, not just because it offers interested

groups and individuals a forum for conveying and

advocating certain positions, but because it provides

individuals and groups the opportunity to understand the values and preferences of others and a

chance to refine their own.

Five distinct concepts of the public, each portraying the public in a different capacity, have been

described (239). One concept is the public as market

players-as individuals and their individual preferences. Another is the public as clients—as organized

interests that “lobby” decisionmakers. The third

concept is the public as patients—as persons or

groups who are affected by policies and decisions.

The public can also be viewed as consumers-as

persons interested in using goods and services (in

contrast to simply expressing their preferences).

Finally, the public can be viewed as functionaries—

as the interests of producers (owners and laborers) in

making and selling resource-based goods and services.

Distinguishing among these concepts can be

instructive to administrators considering how to

involve the public in planning, but there are two

limitations to this approach. First, various individuals and groups may fit within different concepts at

different times-acting, for example, as a client on

one day or in one setting, and as a consumer on

another day or in another setting. In addition, all of

these concepts divide individuals from one another;
Chapter 5--Public Involvement in Forest Planning ● 89

none include the political identity of the public as a

whole-the public as citizens (239). Nonetheless,

viewing the public with these distinct concepts,

portraying the public in various roles, can help

decisionmakers understand the interests and motivation of the individuals and groups who participate in

forest planning.

Forest Service administrators commonly use a

“market imagery’ model of the public (141). The

public is typically viewed narrowly, as individual

competing and conflicting interests, as ‘‘a gaggle of

consumers shopping for policies from shelves

stocked by government experts” (141). Thus, public

participation emphasizes: 1) the need to “inform and

educate” the public about agency programs and

activities, and 2) the collection of opinions from a

wide variety of interests, to be sure all views are

represented. Those opinions are then weighed against

resource management concepts, costs, and legal

constraints, with agency decisionmakers choosing

alternatives they believe best meet the expressed

interests (49, 203, 330). Such an approach is

generally insufficient because it emphasizes ‘ ‘representation’ rather than ‘ ‘accommodation’ of multiple interests (49, 330). The incomplete or inaccurate

picture of the publics, which can result from relying

principally on the market imagery model, may lead

agency planners to miscalculate the political feasibility of final plans and decisions.

A broader view of the public, on the other hand,

can encourage mutual understanding. Public involvement in planning and decisionmaking not only

offers a forum for conveying concerns and advocating positions, but also provides an opportunity to

understand the values and preferences of others and

a chance to build on common bonds. Open discussions and joint fact-finding can also improve understanding of the issues and conflicts underlying

decisions, and thus produce insights into how and

why specific decisions are made (330). Understanding is essential to building trust among the participants (the public and the agency employees). Effective public involvement can, therefore, encourage

trust, and thus acceptance of the final plans and

decisions (49, 203, 330). An appreciation of the

significance of effective public involvement in

developing implementable plans can lead agency

managers to develop effective procedures to involve

the public.

Open Decisionmaking or Decision Building—

An ongoing interchange among diverse interests and

the agency is needed to reflect informed public

opinion and/or consent in the goals and objectives

for land and resource management (306). Planning

and decisionmaking is a learning process, and

models of participation should, therefore, encourage

two-way communication, which allows the agency

and the general public to learn from each other (203,

231). The agency and the public should each be

viewed as contributors to the process, with different

responsibilities.

Problems in public management of natural resources and environmental quality necessarily involve technical, biophysical questions-e.g., what is

feasible, what results from specific practices, what

various practices cost. They also involve human,

socioeconomic questions, as well—e.g., what

should be the goals, what values are important, what

practices are acceptable (29, 306). The latter are

questions of value, and ‘‘only the public is able to

provide adequate insights into the social or human

aspects’ (29) (emphasis in original). Professionals

have no special training for determining what is

socially desirable (15). One major objective and

challenge of the planning process is to balance

‘‘traditional democratic notions of citizen involvement in government with the countervailing need for

technical competency and efficiency of the technocratic society” (92, 306). Thus, on those issues

involving inherently value-laden questions, more

politically acceptable decisions could be made

through a more collective, collaborative decisionmaking process.

Public participation can lead to more collective

planning and decisionmaking, if conducted in a

manner that encourages dialogue or deliberation

among the agency and interested individuals and

groups (203, 231, 330). Public deliberation over

public issues is the “foundation of democracy”

(203).

Such deliberation can lead individuals to revise

opinions (about both facts and values), alter premises, and discover common interests. Disagreements

and inconsistencies encourage individuals to balance

and rank their wants. The discovery that solely

personal concerns are shared empowers people to act

upon them (203).

Furthermore, socioeconomic considerations enter

each stage of the decision process (3, 330). Thus,
90 ● Forest Service Planning: Accommodating Uses, Producing Outputs, and Sustaining Ecosystems

public involvement should aim for sustained interaction among the agency and the interested publics

throughout planning and implementation (29, 306).

More collective decisionmaking that welcomes

public views and considers them seriously is “open

decisionmaking” (228, 277). It encompasses many

of the concepts described above--sustained interaction among the agency and public interests, honest

sharing of information and opinions, and clear

description of how decisions were reached. Thus,

open decisionmaking effectively leads to the “public dialogue” that is the essence of collaborative

decisionmaking.

Shannon (231) suggests that the Forest Service

replace the vision of “decisionmaking’ with “decision building. ” The sole decisionmaker is replaced

with a leader who helps the agency and the public

jointly build acceptable decisions. Thus, the manager becomes responsible for organizing people

(employees and the publics) and information, to

develop the knowledge and commitment necessary

to choose a course of action (52). This model of

decision building recognizes that decisions require

considerable effort by all interests, and that the

process must be coordinated so that the “pieces fit

together” (231).

Clearly, decision building, open decisionmaking,

or collaborative planning would require a change in

Forest Service planning and decisionmaking.3 Greater

public involvement in plannin g and decisionmaking

likely will impose greater duties and responsibilities

on the managers, many of whom are already

stretched to their capacity to perform their required

duties. However, if people are involved-if they

help build the decisions and understand why decisions are made-they will not only be more likely to

accept the decision, they will also contribute to its

implementation. If the agency is to get out of the

courts, public participation must effectively involve

the public.

Manager Responsibilities-A change from decisionmaker to decision builder does not eliminate

managers’ responsibility for their decisions. However, the focus of efforts is altered. Rather than

functioning as an arbiter, managers would function

more like brokers. They would solicit, organize, and

facilitate public participation and debate and seeking

mutually beneficial tradeoffs and compromises

through discussions with and negotiated settlements

among the various interests (49). Discussions of

interests, as opposed to declarations of positions,

lend a less adversarial and more collaborative

atmosphere to the planning process (83, 330). Thus,

an administrator would ‘‘fimction less like . . . [a]

‘neutral’ manager . . . [and more like a] teacher and

guide” (203).

The professional has the responsibility to provide

the public with the basic information required to

understand problems and to recognize what is

involved in the decisions that are made. Once the

public has set its goals, the professional can help by

applying technical skills in the attainment of those

goals (29).

Agency managers can also advise on the physical,

technical, and practical feasibility of whether the

expectations and goals can be achieved. Managers

thus lead in the debate, as well as provide technical

expertise (49).

Managers reevaluating the public’s role in decisionmaking 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 of

influence should they possess. By addressing these

questions, the agency can provide its managers with

direction on the purposes and objectives of public

involvement, and the public with a clearer indication

of how its input will be used in making final

decisions. This, in turn, would provide the public

with a greater incentive to become involved.

A modified organizational structure may be required to involve the public effectively. The resourceoriented structure may inhibit the open, wideranging discussions inherent in open decisionmaking. Furthermore, periodic reevaluation to determine

whether the current structure supports successful

planning and implementation is fundamental to

effective strategic planning (70, 101). Thus, reexamining the roles of agency managers and the public in

the decisionmaking process might prompt the agency

to revise its internal structure and adopt new

techniques that better promote public involvement.

Once administrators determine when and why to

involve the public, they should focus on effectively

promoting 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 potentially interested individuals and groups. Incentives

to 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 and

appeals processes, and in the court--each open to

various degrees of public involvement. Understandably, persons and groups will be more inclined to

participate in the forums where they believe that

their participation will have the greatest impact (80,

230).

Finding the right formula for facilitating public

participation is admittedly difficult. The suitability

of methods and procedures varies with the nature of

the decisions, the geographical setting, and the

preferences of the local publics. For example, a town

meeting might work well for public involvement in

parts of New England, where town meetings have a

rich history, but might not work at all in other parts

of the country; similarly, some individuals are

uncomfortable participating in public hearings, preferring letters or personal interaction. Whatever

procedures are chosen, managers should encourage

the public to participate by responding clearly to

their concerns, and stimulate deliberation and debate. Without incentives to participate in agency

planning and decisionmaking processes, citizens

and interest groups often seek out other forums, such

as Congress or the courts, to influence forest policy

and decisionmaking (203, 231, 330).

Forest Service Efforts To Improve Public Participation--The Forest Service has recognized the

importance of public participation in national forest

planning and management. The agency recently

reviewed its public participation practices (among

other things), and the review team made a series of

recommendations to improve the effectiveness of

public participation (277). They emphasized the

importance of achieving consensus among interested publics and the need to train agency personnel

in communication, mediation, and facilitation skills.

They also noted that the traditional resourceoriented approach to funding is inhibiting integrated

planning and management (276).

Pursuant to this review, the Forest Service has

begun the process of revising its regulations to guide

the implementation and revision of forest plans

(287), and has revised its forest plan implementation

training course. In the proposed revisions of the

regulations, the agency has embraced the findings

297-904 0 - 92 - 4

and recommendations of the review and has announced its commitment to strengthen the role of

public participation in agency planning and decisionmaking. Public participation processes are recognized as attempting to achieve “informed consent’ among the interested publics, and the proposal

thus casts the public in a more specific, direct, and

active role in planning and decisionmaking. In

addition, the proposed regulations encourage the

practice of “conflict resolution” as a tool for public

involvement. (See box 5-A.) This suggests that more

collaborative public participation activities may

become more commonplace.

Furthermore, observers have cited several national forests where public participation efforts are

considered relatively successful, and suggest that

their experiences can serve as models for other

forests (149, 330). Wondolleck (330) cites seven

national forests where managers have successfully

established collaborative public participation processes to develop final forest plans or to avoid

administrative appeals of those plans. Shands (228)

described open decisionmaking as applied in North

Carolina. Thus, the Forest Service has success

stories to show that public involvement in national

forest planning and decisionmaking can work.

Measuring the Effectiveness of Public

Involvement in Forest Planning

Developing criteria by which to measure the

effectiveness of public involvement is important for

at least two reasons. First, measures of effectiveness

can provide clearer direction to managers in the field

on the goals and objectives of public involvement

and on the role of the public in planning and

decisions. With a clearer picture of the goals and

objectives of public participation, managers could

have abetter idea of how to respond to public input.

Second, public participants would have clearer and

more realistic expectations of how their input would

be used, providing an incentive to participate in

planning and in building decisions.

Because of the intensely political nature of forest

planning, measuring the effectiveness of public

participation activities in forest planning and decisionmaking can be elusive (203). Neither NEPA nor

NFMA contain measures by which to gauge the

effectiveness of public participation efforts. There

are no substantive guidelines for how the agency

should consider and respond to public input. In

addition, courts are generally deferential to agency
92 ● Forest Service Planning: Accommodating Uses, Producing Outputs, and Sustaining Ecosystems

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, the

individuals or groups who are dissatisfied with the plans or decisions will turn to administrative appeals or litigation

to 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/or

negotiation aimed at producing mutually acceptable solutions to disputes or controversies (21, 171). ADR

encompasses 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 otherwise

solve problems and settle disputes. Mediation involves a neutral third-party mediator or facilitator to assist the

parties in resolving their differences, but the mediator has no authority to impose a settlement. Arbitration is similar

to 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 parties

together (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 successfully

to resolve disputes involving a wide variety of environmental and natural resource issues, such as land use, water

resources, air quality, energy, forest land and resource planning and management, and toxics (21). Negotiated

rulemaking and Superfund mediation by the U.S. Environmental Protection Agency (EPA) are perhaps the best

known examples of the use of ADR by a Federal agency (21, 203, 204), and legal challenges to EPA rules have

declined considerably since they began negotiated rulemaking (300). In addition, the Administrative Conference

of 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 and

for resolving administrative appeals of plan and projects. The 1989 revision of the administrative appeal regulations

encourages the use of ADR to settle appeals (36 CFR 217.12(a)), and the proposed revision of the forest planning

regulations encourage conflict resolution at all stages in the forest planning process (287). Furthermore, Chief

Robertson 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 national

forests 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 processes

to develop final forest plans or to avoid administrative appeals of those plans. For example, the draft forest plan for

the Monongahela National Forest in West Virginia received widespread public criticism. In anticipation of

administrative and legal challenges, agency planners invited interested groups and individuals to work closely with

them 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 Chattahoochee/Oconee, and the Nebraska--agency managers also used ADR techniques to resolve contentious

administrative appeals.

Negotiation at the planning and appeals stages can be a valuable tool for bringing diverse interests together

to resolve complex disputes (21, 22, 243, 330). Bingham and DeLong (22) noted that the use of ADR techniques

in 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; and

5. 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 resolve

administrative appeals and litigation after plans bave bccm completed or decisions made.
Chapter 5-Public Involvement in Forest Planning ● 93

The promise of ADR in forest plan development is that voluntary negotiated agreements can reduce the

likelihood 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 to

accommodate all interests, and then must defend their plans and decisions from administrative and legal challenges

by dissatisfied interests (330). A more cooperative and interactive process for plan development and implementation

can engage the publics proactively--managers invite forest users and other interested groups and individuals to

jointly develop a plan that is acceptable to all (330). A mediator or facilitator can coordinate the process and help

parties to develop final decisions that are more defensible (and less likely to need defense) than those made without

direct public consultation and collaboration (330). The neutral third party is particularly useful when trust among

the participants is low. The principle underlying ADR can serve as a foundation for building these proactive and

collaborative 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 when

traditional 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 than

more traditional mechanisms, although research has not fully documented the savings (21). Nonetheless, ADR has

provided 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 generally

believe 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 ADR

can resolve many disputes over national forest planning and management, Congress and the Forest Service have

considered 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 use

ADR by providing greater predictability on how public participation might affect final decisions, and might

encourage the participants to initiate negotiations themselves (22). Clearer direction on the use of ADR could also

benefit managers by providing clearer standards and guidelines on when and how to use ADR, whether to engage

a mediator, and how to convene all the necessary parties. By building a certain measure of consistency in ADR

procedures, such standards and guidelines might reduce the likelihood that the process will be misused. Clearer

direction might also make enforcement of negotiated agreements easier (21).

Proponents of institutionalizing ADR stress that the objectives should be to: 1) achieve some consistency in

procedures, and 2) preserve the flexibility of the agency and the parties to shape the process to meet the needs of

the particular circumstances (21, 22, 330). Achieving both objectives is admittedly a difficult task. Several

suggestions 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 of

ADR 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 which

to affect the decision (22). Nonetheless, by negotiating early in the planning process, the Forest Service can

discourage 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 mediator

can 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 resolution

and 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. Excluding

critical interests will lead to controversy later, and could result in appeals or litigation. Thus, negotiations must

accommodate a balanced and fully representative body of interests (22, 330). Furthermore, under NEPA and

NFMA, all interested individuals and groups have an equal right to participate in the forest planning process.

(continusdon fh9xtp4u81
94 ● Forest Service Planning: Accommodating Uses, Producing Outputs, and Sustaining Ecosystems

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 regulatory

mandates, promotes certain organizational interests, and may have an interest m Particular outcomes (22, 50)-a

mediator can be particularly useful and lend some perceived fairness to the process. A mediator may not be

necessary, however, in cases where there are only a few parties, the issues are well-defined, and all the parties

believe 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 less

time-consuming than appeals and litigation, but observers caution that ADR is not necessarily more expeditious

than litigation or other decisionmaking processes. Furthermore, some stress that deadlines are important and

should be established at the outset, considering the number of parties involved, the type and number of issues

in question, the stage of the decisionmaking process, and any other relevant circumstances (22). To preserve

flexibility, deadline extensions could be allowed (22). However, other interests may be affected by delays in

decisions, 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 be

challenged and thus are more likely to be implemented. But since such processes are time-consuming and

potentially costly, some assurance that the agreement will be implemented may be a necessary incentive to obtain

cooperation (22). However, providing sufficient assurance maybe difficult, because the agency must still comply

with the requirements of NEPA, NFMA, and the other laws that apply to forest planning and management.

Limitations of ADR

Not 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 unlikely

to be successful unless the issues in dispute are well-defined. ADR can be useful for specific, narrowly defined

issues, 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 of

participants, but excluding some critical interests could lead to litigation (25, 198). Furthermore, the parties may

have significant differences in expertise and/or power, leaving some at a dative disadvantage (5, 25). Those

perceiving their relative disadvantage might compensate for it by abandoning the ADR process and turning to

Congress or the courts where they may have relatively greater power (201). Because of these potential

disadvantages, the question of whether ADR is appropriate for resolving of a particular dispute or conflict is best

determined by the parties themselves.

Finally, the use of ADR does not always lead to solutions. First, ADR is not free, and only saves time and

money 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 be

implemented (22), they confront the same technical, financial, and administrative difficulties faced by other plans

and decisions (21). Thus, ADR is not a panacea, but simply one more useful tool in the planning and management

of the national forests.

decisionmakers. Discretionary decisions, such as resolution (279). The critique also identified several

how to balance competing public interests, are reasons for improving the effectiveness of public

typically upheld by the courts unless the decisions participation in the planning process (276):

are clearly “arbitrary and capricious’ or the result

of an “abuse of discretion. ’ In such cases, the plans 1.

may withstand administrative appeals and legal

challenges, 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 participation: 1) whether public participation had affected the 4.

decision, 2) whether the public and the Forest

Service were committed to the plan, and 3) whether 5.

appeals could be avoided through negotiation and

continued intensive public participation or conflict

involving more people leads to better, more

acceptable decisions;

challenges to the decisions can be avoided

through informed consent;

challenges (appeals or litigation) can be withdrawn by resolving the dispute;

decisions are more defensible if the public has

been involved; and

trust and credibility lead to general commitment to the decision, and eliminate ‘‘fatal”

challenges to implementation.
—

Chapter 5-Public Involvement in Forest Planning ● 95

Two assumptions are implicit in these statements.

First, public participation is assumed to be more

effective if all or most of the interested and affected

groups and individuals are involved. This traditional

Forest Service view is a useful but incomplete view

of the public’s role in planning and decisionmaking.

The second assumption is that public participation is

primarily intended to achieve the “informed consent’ of the participants to the forest plans. While

the latter assumption casts the public in a more

collaborative role, the former still emphasizes representation over accommodation.

Wondolleck (330) identified five factors leading

to successful public participation: 1) building trust

among participants; 2) promoting understanding of

the issues and conflicts and of the reasons for

underlying decisions; 3) incorporating conflicting

values; 4) providing opportunities for joint factfinding; and 5) encouraging cooperation and collaboration. These factors could provide a tangible

framework with which to measure the success of

public participation activities for particular decisions. Another observer suggests that plan and

decision effectiveness should be measured by political feasibility, social acceptability, economic justifiability, environmental efficacy, and the technical

competency to implement the decisions made (231).

Even the best and most effective public involvement cannot resolve all conflicts. Individuals and

groups will continue to differ over the important

values to be produced through national forest

management. Effective involvement can build trust

and promote understanding, but some participants

will be unwilling to compromise or accommodate

other values.

Such disputes necessarily lead to alternative

means—traditionally, administrative appeals and

litigation—for solutions. The Forest Service has

increasingly used a variety of techniques, collectively known as alternative dispute resolution (ADR),

to settle disputes outside these traditional avenues.

(See box 5-A.) ADR is not a substitute for decision

building or collaborative planning, but can be an

effective tool for some challenges, because the

issues and participants tend to be more narrowly

defined in administrative appeals and litigation.

ADMINISTRATIVE APPEALS

AND LITIGATION

In recent years, Members of Congress have

expressed concern that the number of administrative

and legal challenges to forest plans and activities

indicate that forest planning has “broken down”

(262, 263). Congress has been especially concerned

over the effects on forest plan implementation—

particularly on timber sales-of delays caused by

appeals and litigation. These concerns have prompted

calls to modify or streamline the systems for

administrative and judicial review. In an effort to

expedite the administrative appeals process, the

Forest Service revised its appeals regulations in

1989. Others contend that delays because of appeals

and lawsuits do not result from flaws in the systems,

but rather are symptoms of interest in and concerns

over national forest planning and management.

Proponents of this argument believe that problems

should be corrected: 1) through improved agency

compliance with NEPA and NFMA, 2) through

improved public involvement during plan development and implementation, and 3) through an end to

congressional management direction (output targets

and resource-specific funding) in annual appropriations.

This discussion examines the role of administrative appeals and litigation in forest planning and

implementation, assesses the nature of problems

attributed to appeals and litigation, and considers

options for reform. Administrative appeals will be

discussed separately from litigation, as the problems

associated with each are different in nature.

Administrative Appeals

The Forest Service is not required by law to offer

an administrative appeals process. Nonetheless, the

agency has maintained various systems for administrative appeals of agency decisions since 1906(1 16).

The systems have varied in formality and complexity; some processes have had standing requirements

and have confined the right to appeal to those in a

contractual relationship with the agency, while

others have permitted any person having a grievance

with particular agency decisions to request additional administrative review (155).
96 ● Forest Service Planning: Accommodating Uses, Producing Outputs, and Sustaining Ecosystems

The Current Administrative Appeals System

The Forest Service currently has three sets of

procedures for administrative reviews of agency

plans and decisions. One set, 36CFR251.82, is used

only for reviews of occupancy and use decisions,

and is available only for the affected party. A second

set, 36 CFR 211.16, provides an expedited system

for requesting review of rehabilitation decisions

following natural catastrophes, such as salvage sales

following forest frees. However, most appeals, and

concerns over the appeals process, are under the

regulations, 36 CFR 217, governing the appeal of

NEPA-related decisions (including forest plans and

activities under those plans). The following discussion focuses solely on this appeals process.

The current system of administrative appeals

within the Forest Service is relatively informal in

nature. In contrast to the appeals systems in some

Federal agencies, the Forest Service appeals process

is not adjudicatory in nature-no administrative law

judges or independent hearing officers review administrative decisions. The Forest Service’s process

is better characterized as an extension of public

participation under NEPA and NFMA than as an

adjudicatory process, because any interested party

can file an administrative appeal on a forest plan or

a NEPA-based decision on a specific project or

activity that flows from a plan.

Appeals are made to reviewing officers, the direct

supervisors of the decisionmakers. A second level of

review can be requested, but the second review is

discretionary, not a right of the appellant. For

example, since forest plans must be approved by

regional foresters, appeals challenging those plans

are reviewed by the Chief of the Forest Service, with

discretionary review by the Secretary of Agriculture.

Likewise, decisions made by the forest supervisors

are appealable to the regional forester, with discretionary review by the Chief. The reviewing officers

can fully or partially affirm or reverse the original

decisions, or may, under certain circumstances,

dismiss appeals without review. The reviewing

officers may also request that the deciding officer

attempt to resolve or settle the issues in dispute with

the appellants. (See box 5-A.)

Not all decisions are subject to review under 36

CFR 217. Only decisions recorded in a NEPA

document (i.e., a Record of Decision, a Decision

Notice, or a Decision Memo, and the related

environmental disclosures) are subject to appeal

under these regulations. Consequently, appealable

decisions include timber sales, road and facility

construction, forest pest management activities,

measures to improve wildlife and fisheries habitat,

and so forth. However, policy directives, agency

handbooks, and other guidance for forest planning

and management that do not require NEPA documents are not appealable. The regulations also set

time limits on filing and processing appeals. However, the review period can be extended, to allow for

the disagreement to be resolved through other means

and for other reasons. Following a fina1 decision on

an appeal, an appellant can seek judicial review of

that decision in Federal district court under the

Administrative Procedures Act.

The Current Appeals Situation

Many members of the public and of Congress are

concerned over the number of administrative appeals, and the time and expense involved in processing them. In 1989, the General Accounting Office

(GAO) reported that the total number of administrative appeals filed annually had more than doubled

between 1983 and 1988, from 584 to 1,298 (252).

Much of the increase can be attributed to the

completion of forest plans; in 1983, forest plan

appeals accounted for less than 1 percent of the

appeals, but in 1988 they accounted for more than a

quarter of the total appeals of NEPA-related decisions (252). However, appeals of timber sales also

increased during this period (252). The total number

of new appeals fell in 1989, but rose again in 1990

and increased substantially in 1991 (although 60

percent of the increase was attributed to one

decision) (111,285).

The time needed to process appeals also rose

significantly during the 1980s. The average processing time increased from 201 days in 1986 to 363

days by 1988, an increase of more than 75 percent,

and more than 250 percent longer than is provided in

the regulations (252). Appeals of forest plans

generally require more processing time than other

appeals (252), and thus some of the increase in time

is the result of the increase in appeals of plans. In

addition, the backlog of unresolved appeals has

increased from 64 at the end of 1983 to 830 at the end

of 1988, with forest plan appeals accounting for 44

percent of the backlogs in 1988, and to more than

1440 at the end of 1990 (1 11).

The cost of handling and processing appeals has

also generally risen. The Forest Service reports that
..—

Chapter 5-Public Involvement in Forest Planning ● 97

servicewide costs for appeals (excluding costs

incurred by the U.S. Department of Agriculture’s

Office of General Counsel) increased from approximately $2.8 million in 1983 to $10.1 million in 1988

(285, 300). Cost data for fiscal years 1989 and 1990

indicate that annual costs have decreased to approximately $7.8 million (285).

The increases in appeals appear to be due both to

concerns over the emerging forest plans and to

increasing concerns over timber sales in some areas.

Although many appeals are described as harassment,

especially when many timber sales on a forest are

appealed, most appeals appear to be justified,

because 90 percent have been reversed or remanded

(300), with additional appeals reversed or remanded

at the second-level, discretionary review (285). The

majority of the reversals was because of NEPArelated problems (1 16).

The increase in processing times appears to be due

to problems in complying with the appeals system,

rather than with the system itself. GAO (252) found

that, nationwide, the Forest Service was responsible

for 94 percent of the total time overruns beyond the

basic time provided for appeals in the regulations.

These problems have resulted primarily from the

difficulties in responding to the growing number of

sophisticated challenges to the environmental analyses by the Forest Service (252). Because NEPA has

largely been interpreted through litigation, the Forest Service often must incorporate new standards

and requirements into its pending appeal decisions,

causing added delays. Nevertheless, the Congressional Research Service (CRS) echoed GAO’s

finding that the appeals system is not necessarily a

problem in and of itself (300).

The administrative appeals process has been a

valuable tool for the Forest Service. It has provided

an internal mechanism for clarifying the legal

requirements and for testing the soundness of

decisions and the appropriateness of current policies

and procedures (155). In addition, the appeals

process can lead to better and more consistent

decisions by encouraging more responsibility and

accountability 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 plans

and those made during implementation, and 3) the

standards for the environmental analyses required by

NEPA (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 sale

quantity (155). Other issues addressed in administrative appeals have included guidance on management

indicator species and biological diversity, and adequacy of resource monitoring plans (155). Because

the appeals process has forced the agency to address

and resolve novel and complex questions under

NEPA and NFMA in this frost round of plan

development, revising forest plans may be easier

than preparing the initial plans (155).

The Forest Service revised its appeals regulations

in 1989 in response to concerns over the growing

number of appeals filed against final forest plans and

to the significant increase in the amount of time

needed to resolve those appeals, In addition, the

Forest Service has recently initiated new efforts to

rectify deficiencies. In January 1991, the agency

began using its revised forest plan implementation

training course. The course is designed to address

various shortcomings, especially compliance with

the analysis and documentation requirements of

NFMA and NEPA. It is too early to tell whether

these changes will ameliorate the conflicts surrounding forest management, and thus reduce the number

of appeals and /or their impacts.

Implications and Consequences of Appeals

The implications of the growing number of

appeals, and of the delays and costs they cause, are

not precisely known. Some speculate that the delays

in processing significantly reduce the amount of

timber available for sale, causing serious economic

impacts for local communities (252). Consequences

for other resource uses and values are far less

well-known, and are rarely debated, but should not

be ignored. Nevertheless, the following discussion

focuses on the impact of appeals on timber available

for sale.

The available evidence does not support the

assertion that administrative appeals have significantly decreased the volume of timber available for

sale. GAO (252) concluded that, although impacts

on timber availability vary by region, appeals of

forest plans and activities have not significantly

affected or delayed timber sale volume nationwide.

In fiscal years 1986 and 1987, appeals were filed on

only 6 percent of the total volume of timber offered

for sale, and less than 1 percent of the total offered
98 ● Forest Service Planning: Accommodating Uses, Producing Outputs, and Sustaining Ecosystems

volume was delayed by those appeals (252). Furthermore, less than 6 percent of timber volume sold in

each region, and less than 2 percent nationally, was

delayed in fiscal year 1988 (295). However, these

data exclude appeals resolved relatively quickly (in

the same year they were filed) and meritorious

appeals, where the agency’s decision was determined to be inadequate. Finally, an analysis of the

Forest Service timber program from 1969 through

1988 showed no significant decline in timber

availability that could be attributed to administrative

appeals (301).

Nonetheless, administrative appeals can affect the

timber sale program. The agency attempts to maintain an inventory or “pipeline” of approved timber

sales that are available as substitutes for appealed

sales, thus preventing serious gaps in timber flow.

But, for a number of reasons, the inventory of

planned timber sales with approved environmental

analyses has declined in recent years (252, 300).

According to the Forest Service, this “pipeline”

problem has been more acute in some regions-such

as the Northern Region (Montana and northern

Idaho)--than in others (252). Appeals, in conjunction with inadequate environmental analyses and a

reduction in the number of timber sales for which the

requisite environmental analyses have been prepared, can reduce the flow of timber from the

national forests (301). Furthermore, shortcomings in

the agency timber program data may disguise the

real impacts of appeals on timber availability.

Alternatives to Appealing Plans and Activities

Some have attributed the growth in the number of

appeals and in the processing time to the current

system of administrative appeals. It is argued that,

because any activity can be appealed, the appeals

system is used to force a reevaluation of forest plan

decisions, and to harass authorized uses of the

national forests. However, only NEPA-related decisions can be appealed, and thus policy directives and

guidelines that can affect forest planning and management are not subject to appeals.

Some have suggested replacing the current Forest

Service appeals process. One proposal is to establish

a more formal, quasi-judicial appeals process, similar to that of the Interior Board of Land Appeals in

the Department of the Interior. This system relies on

an administrative law judge (or an independent

hearing officer) to review the record on appeal, and

arbitrate the solution (300). Another suggestion is to

create a ‘‘super board’ to hear appeals of decisions

made by the Forest Service, the Bureau of Land

Management, and possibly other land managing

agencies, such as the National Park Service and U.S.

Fish and Wildlife Service (300).

More typical proposals would change the current

system of administrative appeals practiced by the

Forest Service, rather than revise it wholesale (262).

One suggestion is to require appellants to have

participated in the planning process or to demonstrate that they would be directly harmed by the

decision. Another proposal, to assure that the

appellant is serious about the challenge, is to require

a filing fee for appeals. A third approach is to shorten

the time allowed for filing and processing, thereby

reducing the delays caused by appeals. Another

suggestion is to restrict appeals of activities to

consistency with the plans, although how this fits

with tiering of site-specific activity documentation

and programmatic forest plans is unclear. (See ch. 4.)

A fifth recommendation is to require negotiations

before the reviewing officer examines the appeal.

This might eliminate some appeals, particularly

those resulting from misunderstandings, but is

inconsistent with successful use of alternative dispute resolution. (See box 5-A.) In general, these

proposals restrict access and/or expedite the process,

and therefore attempt to eliminate “unnecessary”

appeals and accelerate implementation of forest

plans and activities.

Changing the current administrative appeals system might not yield the desired results, however.

The GAO findings suggest that the problems are not

principally due to the system; the delays and time

overruns were mostly attributable to the agency’s

inability to meet the deadlines (252). Furthermore,

the agency reversed or modified its decisions in 40

percent of the timber sale appeals resolved in

Washington, Oregon, Montana, and northern Idaho

between 1985 and 1988 (252). Thus, appeals have

apparently played a significant role in exposing

inadequate environmental analyses and documentation. If the current system is modified to reduce

access or expedite processing, it may simply lead to

more litigation by dissatisfied parties.

The Forest Service revised the appeals regulations

in 1989 to expedite appeals processing. The impact

of the changes is not yet fully known, but the

second-level “discretionary review procedure does

not appear to be working’ (285). To the extent the
Chapter 5--Public Involvement in Forest Planning ● 99

changes do not reduce the number or processing time

of appeals, additional changes may be warranted.

The Forest Service is also encouraging the use of

alternative dispute resolution to avoid and/or settle

appeals (116). Such a technique can be effective for

settling disputes, and thus is a valuable alternative to

administrative and legal challenges. More effective

public participation and more widespread use of

alternative dispute resolution in planning and implementation may result in fewer appeals of plans and

projects.

Ultimately, forest planning and implementation

involve a host of complex political and technical

questions. Administrative appeals constitute a valuable check on Forest Service decisio nmaking by

providing additional admini strative review of sometimes highly controversial plans and projects. Appeals provide the public with a final administrative

opportunity to question the appropriateness of decisions on land use, resource allocation, and standards

and guidelines. As NEPA has been interpreted by the

courts, administrative appeals have helped the agency

to assure that decisions are modified when necessary

to comply with NEPA requirements. Appeals have

also encouraged consistency and accountability

throughout the National Forest System. Thus, many

of the features of the current system should be

retained. Modifications could expedite the process

while preserving the general purposes and structure

of the system. Solutions that focus on correcting

management problems responsible for some of the

appeals can improve plan implementation.

Litigation of Plans and Activities

Many in Congress are also concerned that litigation of forest plans and activities has led to

intolerable delays in implementing those plans and

activities (263). Some even suggest that appeals and

litigation are often used “offensively” to delay

implementation of the plans for as long as possible

(28). This section briefly examines the role of the

courts in the Federal forest planning process, describes the impacts of litigation on forest plan

implementation, and discusses some options for

reform.

Judicial Review

Neither NEPA nor NFMA expressly provide for

judicial review of forest plans and activities. Nonetheless, since the passage of these two laws, the

courts have played an increasingly significant role in

forest planning and implementation.4 Federal courts

exercise jurisdiction over forest planning under the

Administrative Procedures Act.5 APA authorizes

Federal courts to review Federal agency actions,

except when a statute precludes judicial review of a

particular action or commits the decision to agency

discretion. Standing requirements are fairly broad:

any person ‘‘suffering a legal wrong because of

agency action, or adversely affected or aggrieved by

agency action within the meaning of a relevant

statute, is entitled to judicial review thereof” (5

U.S.C. 702). The law once required persons to

demonstrate pecuniary damage to obtain judicial

review of agency actions, but such direct financial

interests are no longer necessary.

The 1897 Organic Act and MUSYA vested

significant management authority in the Forest

Service, with relatively few constraints on the

agency’s discretion to allocate resources or to

regulate the occupancy and use of the national

forests. Consequently, prior to NEPA and NFMA,

most agency actions were essentially immune from

close judicial review (324). However, NEPA and

NFMA contain a number of procedural and substantive requirements for forest planning and management, and thus subject agency decisions to closer

scrutiny by the courts. In addition, several environmental laws, including the Endangered Species Act,

contain provisions authorizing private citizens to

challenge agency actions in court.

Courts can prohibit the Forest Service from

implementing a plan or pursuing a particular action

if the agency fails to comply with procedural or

substantive requirements of NEPA and NFMA.

However, except for clear violations of statutory

procedure or substance, courts remain relatively

deferential to agency expertise and discretion, and

will generally uphold agency actions unless they are

shown to be arbitrary and capricious or an abuse of

discretion. 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 in

filifiihng 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).
100 ● Forest Service Planning: Accommodating Uses, Producing Outputs, and Sustaining Ecosystems

what by the ‘‘hard look’ standard of judicial review.

(See ch. 4.)

Implications and Consequences of Litigation

In contrast to the substantial and growing number

of administrative appeals, relatively few Forest

Service plans and activities are litigated. Of the

roughly 500 forest plan appeals finalized in fiscal

year 1989, only 11 ended up in Federal court (300).

Furthermore, only 32 timber sales were litigated in

fiscal year 1989 (300), out of about 500 timber sale

appeals and 525,000 timber sales. As of March 1,

1991, 6 cases were litigating regional guides (regional direction for forest planning), 15 cases were

litigating forest plans, and 7 other cases were based

on NFMA (289). A total of 66 lawsuits challenging

timber sales were pending as of April 17, 1991,

including 21 challenges in California and 35 in

Washington and Oregon (1 11). Thus, despite claims

that the growing number of legal challenges to forest

plans and activities threatens efficient and effective

forest management, the existing evidence suggests

that the Forest Service is rarely sued over its plans

and activities.

This is not to suggest that the few lawsuits do not

have substantial economic impacts, particularly in

certain regions, such as the Pacific Northwest.

Litigation can often be complex and lengthy, and the

subsequent delays may have a significant impact on

the planning and management of the national forests

at any given time. For example, several lawsuits are

challenging the Regional Guide Amendments on

Spotted Owls, but at least two6 have been stayed

pending resolution of the principal challenge--

Seattle Audubon Society v. Robertson, No. C89-160

(W.D. Wash.). While the exact impact of the spotted

owl litigation is highly debatable, most estimates

suggest that tens of thousands of timber industry

jobs could be affected by the decision. On the other

hand, the plaintiffs obviously believe that the

litigation is needed to protect existing values associated with the old-growth forests. What is clear from

this example is that, while few agency plans and

decisions are litigated, such litigation can have

immense consequences on agency activities over an

extended period.

Possible Reforms for Judicial Review of

Forest Service Plans and Decisions

In an effort to curb some of the impacts of

litigation of Forest Service (and Bureau of Land

Management) timber sales, Congress has enacted a

number of riders to appropriations laws that preclude

judicial review of certain decisions. Between 1985

and 1989, these riders have exempted a broad range

of management decisions from judicial scrutiny.

Riders have been used: 1) to exempt decisions to

resell timber returned under the Federal Timber

Contract Payment Modification Act of 1984 from

judicial review; 2) to proclaim that environmental

impact statements for certain timber sales, roads, and

other activities “shall be treated as satisfying’ the

requirements of NEPA and NFMA and consequently not subject to administrative appeal or

judicial review7; and 3) to preclude judicial review

of challenges to existing plans solely because the

plans are outdated or fail to incorporate new

information (28). Opponents of such provisions

contend that appropriations bill riders circumvent

the legal direction for forest planning in NEPA and

NFMA, and that solutions to forest planning and

management controversies should be made only

after careful review by the authorizing committees

(143).

Other, more comprehensive reforms have also

been suggested (300). One proposal is to legislatively encourage, or even to require, the use of

alternative dispute resolution techniques to avoid or

resolve administrative appeals and litigation. (See

box 5-A.) A second option is to eliminate one level

of judicial review; cases that have completed the

administrative review process would be heard directly in Federal appeals courts, possibly with appeal

directly to the U.S. Supreme Court. Another suggestion is to develop a bifurcated system, whereby

certain issues (e.g., those involving activities under

the plans) go to the district courts, and others (e.g.,

those involving forest plans) go directly to the courts

of appeals. A fourth option is to establish a new

Federal Lands Court to hear legal challenges to land

and resource management plans and activities for

both 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”on

Com”ttee v. U.SF.S., No. 89-139 (D. Oregon).

7~e N~& c~c~t Coti of Ap@s held tit pm of ~srider 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 of

powers doctrine by dictating judicial findings as to the sufficiency of the environmental impact statements.
Chapter 5-Public Involvement in Forest Planning . 101

managing agencies. The opportunities and limitations of such measures were the subjects of a 2-day

workshop sponsored by the Congressional Research

Service in 1989, and a more detailed analysis can be

found in the CRS Report, Appeals of Federal Lund

Management Plans and Activities: A Report on a

CRS Research Workshop (300).

To the extent that plaintiffs are successful on the

merits of their legal claims, and to the extent that

other lawsuits filed have not generally been frivolous or otherwise unwarranted, the current system of

judicial review seems to be serving its intended

purpose. Citizens are allowed an opportunity to

challenge the legal basis for agency plans and

decisions. Thus, judicial review provides a valuable

independent check on the agency’s compliance with

its legal requirements. At least some Members of

Congress seem committed to preserving citizens’

rights to judicial review of forest planning and

management decisions:

The rights of our citizens to use the courts to

protect our forests should not be abridged. We must

find a way to protect our citizens’ rights and our

forests (143).

The available information suggests that the lawsuits filed against the Forest Service generally can be

attributed to the agency’s inadequate compliance

with NEPA, NFMA, and other laws, such as the

Endangered Species Act and the Clean Water Act.

Improved compliance with applicable law is likely

to reduce the successful legal challenges to Forest

Service plans and decisions. Thus, the immediate

challenge is to make the planning process work more

effectively and efficiently, while preserving the

basic function of the courts.

Much of the current controversy over administrative appeals and litigation has arisen because of one

issue—the protection of spotted owls and oldgrowth forests in the Pacific Northwest. It seems

premature to revise the nationwide judicial review

process for forest planning and management because

of one admittedly calamitous clash of values.

Changing the judicial review process appears to be

an attempt to resolve the substantive debate about

the fate of old-growth forests, without forcing

Congress to choose between forest protection and

timber production. Further study and analysis of

ways to expedite forest management-related litigation may be warranted. In the meantime, however, it

may be more pressing to address managementrelated problems that have led to agency failures to

comply with planning and environmental laws.

STATE, TRIBAL, AND LOCA L

GOVERNMENT PARTICIPATIO N

Other Federal agencies and non-Federal government organizations have additional requirements

and opportunities to participate in Forest Service

planning. The requirements generally revolve around

State jurisdiction over water and wildlife. In addition, MUSYA and NFMA provide for Forest Service

coordination with State, tribal, and local governments and other Federal agencies in the planning and

management of the national forests. Finally, States

and local governments have interests in national

forest management, which may go beyond the

traditional consideration of direct employment and

income generated by national forest outputs.

State Legal Responsibilities

The legal framework governing national forest

planning and management generally recognizes

State responsibility for water rights and for fish and

wildlife. The 1897 Organic Act specifies that:

All waters within the boundaries of forest reserves

may be used . . . under the laws of the State wherein

such reserves are situated . . .

State jurisdiction over national forest waters is

implicit in MUSYA, since MUSYA is to be ‘‘supplemental to, but not in derogation of, the purposes

for which the national forests were established as set

forth in the Act of June 4, 1897.” Furthermore, State

authority over fish and wildlife is expressly provided

in section 1 of MUSYA:

Nothing herein shall be construed as affecting the

jurisdiction or responsibilities of the several States

with respect to wildlife and fish on the national

forests.

Since NFMA directs that land and resource management planning for the national forests is to be

consistent with MUSYA, NFMA also implicitly

endorses State authority over the waters and the

wildlife of the national forests.

In addition to these directions in the 1897 Organic

Act and in MUSYA, the Wilderness Act and the

Wild and Scenic Rivers Act of 1%8 expressly

provide for State jurisdiction over water rights and

wild animals. Section 4(d) of the Wilderness Act

specifies that:
102 . Forest Service Planning: Accommodating Uses, Producing Outputs, and Sustaining Ecosystems

(7) Nothing in this Act shall constitute an express

or implied claim or denial on the part of the Federal

Government as to exemption from State water laws.

(8) Nothing in this Act shall be construed as

affecting the jurisdiction or responsibilities of the

several States with respect to wildlife and fish in the

national forests.

The Wild and Scenic Rivers Act of 1968 provides

similar language for State authority over fish and

wildlife, and then provides much more explicit

guidance on the relationships between State water

rights and efforts to preserve the wild and scenic

qualities of the designated rivers.

In addition to the traditional State authority over

water rights and wild animals, the States set and

enforce water and air quality standards, under the

Clean Water Act and Clean Air Act, respectively. As

noted in chapter 4, States are authorized to establish

standards more stringent than those imposed by the

Federal laws, and Federal agencies must comply

with State standards. Thus, Forest Service practices

must meet the State standards for water and air

quality.

Most States also regulate forest practices--silvicultural techniques, the percentage of a watershed

that can be clearcut within a specified period, and so

forth (114). Since many of these regulations are

imposed 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 State

requirements, however, the Forest Service must, at

a minimum, be aware of State forest practice

regulations and their implication for management of

national forests and adjoining lands.

Cooperation With Other Agencies

Direction for Forest Service cooperation with

other government agencies was frost expressed in

section 3 of MUSYA:

. . . the Secretary of Agriculture is authorized to

cooperate with interested State and local governmental agencies and others in the development and

management of the national forests.

RPA reinforced this direction in its requirement to

prepare land and resource management plans for

units of the National Forest System; such plans are

to be:

. . . coordinated with the land and resource management planning processes of State and local governments and other Federal agencies.

Section 12 of NFMA adds that “information and

data available from other Federal, State, and private

organizations’ shall be used in forest planning.

And, State, tribal, and local governments can also

participate in national forest planning through the

public participation provisions of section 6(d),

As with public participation, agency participation

and coordination is not guaranteed to influence

national forest decisionmaking:

The opportunity to comment on a proposed

federal action does not necessarily give state and

local government any meaningful leverage over

federal land use decisions (55).

Furthermore, the 1982 revision of the NFMA

regulations reduced the emphasis on Forest Service

cooperation with State and local governments (20).

A complicating factor in intergovernmental coordination in forest planning is the variety of State

agencies with an interest in national forest management. At a minimum, States typically have one

agency administering water rights and possibly

enforcing water quality standards, another agency

responsible for fish and wildlife, and a third agency

to manage State forest lands and to regulate forest

practices. These separate agencies often have different, potentially conflicting interests in national

forest planning and management, and it can be quite

difficult for the Forest Service to coordinate with the

State when the State presents conflicting views.

The State of Oregon recognized this difficulty,

and believed that a unified State response would

have greater influence on the plans for the national

forests in the State (20). The State was fortunate to

be able to assemble a small team of experienced

experts, with ready access to the Governor’s office,

to achieve a unified response. In addition, the State

Forestry Department and Oregon State University

had already begun a cooperative assessment of the

timber resources on all timberlands in the State.

Subsequently, the Governor and the Oregon congressional delegation were able to forge a short-term

legislative compromise between timber interests and

environmentalists for continuing timber sales despite the ongoing litigation over spotted owl protection. Finally, the ongoing concern about spotted owl

protection had led to a study of timber management
—.

Chapter 5-Public Involvement in Forest Planning ● 103

options for all landowners. The State’s wealth of

new data on timber resources and timber management, and its ability to reach a compromise among

interests, greatly contributed to its success in influencing the forest plans for the national forests in

Oregon (20).

While the State of Oregon benefited from unique

circumstances, its experience illustrates that a unified response among State agencies provides clearer

input, and thus makes a direct Forest Service

response more feasible. If other States wish to

influence national forest planning, coordinating the

positions of the various agencies and providing a

harmonious stance may be necessary.

Local Concerns

State and local governments also have direct

interests in the management of the national forests.

First, the Forest Service returns 25 percent of its

gross revenues to the States for use on schools and

roads in the counties where the national forests are

located. Thus, State and especially local governments have a financial interest in national forest

management that generates revenues. (For a more

thorough discussion of this concern, see ch. 8.)

In addition, elected State and local officials are

representatives of the people, and thus are surrogates

for the public acting collectively. The public as

citizens is an important role (231, 239), but the

Forest Service typically views the public as individual interests. State and local government participation in forest planning provides one means for

including this important aspect of the public’s

interests. (See ch. 5.)

Finally, State and local governments have a stake

in maintaining the employment and income of their

citizens. Activities in the national forests support

local jobs, and debate over community stability

reflects this interest. (Again, see ch. 8.)

The Federal Government may also have an

interest in maintaining the economic stability of

localities. Under the “fabric-of-government” theory, the multiple levels of government work cooperatively to support the interests at all levels (312).

This position is based on the vision that local and

regional economic health and vigor is in the national

interest, and the Federal Government is, therefore, a

partner in influencing State and local economies. If

one accepts the fabric-of-government theory, then

the Forest Service has a direct interest in cooperating

with State and local governments to maintain their

economies. (The alternative view, the ‘‘assignmentof-powers’ theory, asserts that each level of government has separate and distinct responsibilities. State

and local economies are viewed as State and local

responsibilities; national interests pertain only to

benefits for all Americans or at least multi-State

regions.)

The joint management of forest ecosystems also

generates State and local interest in national forest

management. National forests are part of these

ecosystems, and their management should be coordinated with the management of other forested lands

to protect ecosystem health and productivity. Some

ecosystem requirements, such as wildlife migration

corridors, particularly need some form of coordination among landowners.

States not only have an interest in coordinated

forest management, they also have some responsibility for, and some expertise in, such management

(20). As discussed above, many States regulate

forest practices on at least State and private lands,

Many States also have statewide forest resource

planning programs, funded in part through the Forest

Service’s Cooperative Forestry Assistance Program

(in the State and Private Forestry Branch of the

agency) (102, 103). These State forestry activities—

forestry regulation and statewide resource planning—

implicitly recognize that forests are ecosystems.

Therefore, States have some particular expertise and

interest in coordinating forest management, and

such expertise should be given a full hearing in

national forest planning and management.

SUMMARY AND CONCLUSIONS

Public participation is essential to developing

forest plans that the public will accept as appropriate

management direction for the national forests. Public participation operates at several stages of planning and implementation: during the development

and revision of forest plans; in implementing those

plans; and when requesting administrative and/or

judicial review of agency plans and decisions.

Finally, the public participates through the coordination of Forest Service planning and decisionmaking

with State, tribal, and local governments.
104 . Forest Service Planning: Accommodating Uses, Producing Outputs, and Sustaining Ecosystems

Public Participation

Public participation in Forest Service planning

and decisionmaking is required bylaw. The MultipleUse Sustained-Yield Act of 1960 (MUSYA) requires that management ‘best meet the needs of the

American people,” which can only be determined

by identifying the public’s values and desires. The

National Environmental Policy Act of 1969 (NEPA)

requires agencies to inform the public about the

possible environmental impacts of their decisions,

including the public as a participant in decisionmaking rather than as a mere recipient of information.

Congress reinforced the public’s right to participate in Forest Service planning and decisionmaking

in the National Forest Management Act of 1976

(NFMA). Senator Humphrey, the chief sponsor,

described the public as advisors to agency planners

and decisionmakers. NFMA also authorized the use

of advisory boards in planning and managing the

national forests, but the Forest Service has not used

this authority.

Although the Forest Service has long included the

public in its planning and decisionmaking, the

public remains critical of agency efforts. Recent

studies have shown that the public does not understand 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 has

failed in its public participation responsibilities.

One explanation for the perceived failure is that

the Forest Service model of participation is based on

due process, on receiving full and equal representation of various views and values. Thus, each interest

is forced to argue the ‘‘rightness’ of their position

and the ‘‘wrongness’ of other positions. This

process is divisive and promotes conflict and distrust

among the interests and with the agency. It also

means that “success’ is measured in numbers of

views, participants, and opportunities. Forest Service failures are also blamed on insufficient data on

who the participants are and how they prefer to

participate. Others suggest that the agency resists

meaningful participation because its traditional autonomy and professionalism inhibit listening to

‘‘nonexperts. Finally, some observers have noted

that public participation is limited by the focus on

resource outputs and budgeting and the lack of

managerial incentives for effective participation.

The Forest Service has had numerous successes in

involving the public in national forest planning.

Typically, successful managers have a clear idea of

why the public is to be involved-to determine what

is truly in the publics’ interests. Furthermore, they

often understand the goals of public participation—

to gain insights into the public’s values, to provide

an early warning of potential problems, and to be

accountable to the public. However, the Forest

Service also needs a model of public involvement

that recognizes the various roles of the public: as

individuals, as organizations, as producers, as consumers, and as citizens. This broader view of the

public can lead to open discussions and joint understanding of situations, limitations, and possibilities.

Such a model of public participation leads to a

quite different approach to planning and decisionmaking. Under this approach, sometimes referred to

as open decisionmaking or as decision building, the

agency and the public are both contributors to decisions. Decisions are reached through dialogue and

mutual deliberation, with sustained interaction to

find the common ground and to build acceptable

decisions. This model also suggests that, instead of

balancing interests and adjudicating conflicts, Forest Service managers become leaders in organizing

and facilitating debate and public analysis. This

approach not only involves the public in decisionmaking, it helps the participants to understand why

certain decisions are reached. There is no simple

formula or technique for open decisionmaking or

decision building. The best means of involving the

diverse publics will vary regionally and among

interests.

The Forest Service has recognized the need for

criteria of successful participation, and has suggested that success includes decisions affected by

the public, public and agency commitment to

implementing the plan, and fewer administrative

appeals. Others have suggested that key elements of

success are mutual trust and understanding.

It will not always be possible to develop plans and

decisions that are acceptable to all parties. Alternative dispute resolution techniques can help to resolve

some differences. Such techniques, used in conjunction with open decisionmaking/decision building,

could reduce the conflicts over national forest

management. Nonetheless, the traditional techniques

of administrative appeals and litigation will still be
Chapter 5-Public Involvement in Forest Planning . 105

used occasionally, when differences cannot be

resolved satisfactorily.

Appeals and [litigation

Many members of the public and of Congress

believe that administrative appeals and litigation are

preventing the implementation of national forest

plans, and that this indicates the failure of the

planning system. The number of administrative

appeals-internal, relatively informal reviews at the

request of a member of the public—more than

doubled between 1983 and 1988, and the average

processing time also increased substantially. Much

of the increase can be directly attributed to the

completion of forest plans, although the number of

timber sales being appealed has also risen, and the

Forest Service has not been meeting the regulatory

deadlines for processing appeals. However, the

appeals system has been useful for helping the

agency to cope with evolving standards for meeting

the requirements of NEPA and NFMA.

The increasing number and processing time of

appeals has been described as a problem, particularly by delaying the sale and harvest of timber.

Although evidence of significant delays is lacking,

the aggregate data available could be masking

serious local problems.

Various proposals have been offered to address

the apparent problems of Forest Service administrative appeals. Some would overhaul the system

completely, replacing the current, informal system

with a more structured, formal system akin to that of

the Department of the Interior’s Board of Land

Appeals. Most suggestions would alter the current

system less radically, typically either by restricting

access to appeals through standing requirements or

a filing fee, or by expediting processing through

shorter deadlines or required negotiations. However,

such options could be counterproductive, if the

result is fewer appeals but more litigation.

Litigation—judicial review of agency decisions—

can lead courts to prevent the agency from implementing plans or pursuing actions, if the decisionmaking did not comply with the procedural and

substantive requirements of NEPA and NFMA.

Relatively few administrative appeals of Forest

Service plans or decisions actually lead to litigation.

Currently, only 28 cases are pending over NFMA

decisions, and only 66 cases are pending over timber

sales. Nonetheless, few lawsuits can have immense

consequences. The largest and best known example

is the case over the spotted owl supplement to the

Pacific Northwest Regional Guide, for NFMA

planning in Washington and Oregon. This case

could affect tens of thousands of jobs in the Pacific

Northwest, but the plaintiffs assert that the guide

could allow the extinction of the owl and the

elimination of other values associated with the

old-growth forests the owls inhabit.

Some problems resulting from litigation of Forest

Service planning and decisionmaking have been

addressed with riders on the annual Forest Service

appropriations to preclude judicial review of specific decisions or on certain bases. Such riders have

become increasingly controversial, as the authorizing committees recognize the increasing use of

appropriations to establish management direction

for the national forests. Other reforms have been

suggested, such as requiring the use of alternative

dispute resolution techniques, eliminating one level

of judicial review, developing a bifurcated system

(with some decisions reviewed by district courts and

others reviewed initially by appellate courts), or

establishing a new Federal Lands Court.

However, one must be careful in revising the

current system of judicial review for Forest Service

planning and decisionmaking. Successful litigation

suggests that the Forest Service is not complying

with its legal requirements. If the requirements

cannot be met, Congress should consider changing

the laws, not simply preventing the laws from being

enforced. Furthermore, much of the current controversy is over the spotted owl. Some have suggested

that Congress is attempting to avoid the appearance

of choosing sides in the debate, and is attempting to

resolve the substantive issue by altering the system

of judicial review. It maybe inappropriate to change

the system because of one, albeit monumental,

lawsuit.

State and Local Government Participation

State, tribal, and local governments have particular interests in national forest planning and management. States have jurisdiction over and responsibility for certain resources, such as water rights and fish

and wildlife management, and the laws governing
106 . Forest Service Planning: Accommodating Uses, Producing Outputs, and Sustaining Ecosystems

Forest Service planning and decisionmaking preserve these State rights. Furthermore, many States

regulate forest management practices, at least on

State and private lands. Thus, cooperation between

the Forest Service and the relevant State agencies is

an important part of national forest planning.

MUSYA and NFMA require the Forest Service to

cooperate with State and other government agencies.

However, cooperation does not provide the States or

other governments with any meaningful leverage to

influence plans or decisions. The State of Oregon,

through a fortunate combination of people and

circumstances, was relatively successful at influencing national forest plans. The State coordinated its

various agencies for water quality, forest practices,

fish and wildlife management, etc., and thus provided harmonized responses to the forest plans. The

success of their efforts strongly suggests that consistent, coordinated State responses to Forest Service plans and decisions are more likely to be

influential than independent agency responses.

Finally, State and local governments have additional interests in maintaining their economies and

in sustaining ecosystems. The fabric-of-government

theory suggests that the Forest Service is a partner in

supporting regional and local economies. Furthermore, State and local governments represent the

public acting as citizens, and thus represent particular interests that are relevant to land and resource

management planning. Finally, coordination among

the various landowners is necessary to sustain

ecosystems. States, through their forest practice

regulations and their State forest resource planning,

have expertise and knowledge to offer in coordinating management of multiple landowners.
Chapter 6

Biological Dimensions

of Forest Planning
Contents

Page

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

109

109

111

111

112

114

115

115

115

117

117

117

119

121

123

Box Page

6-A. Example of Levels of Monitoring on a Nationa1 Forest . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 116

Table

Table Page

6-1. National Forest Plans Sampled for Inventory and Monitoring Reviews . . . . . . . . . . . . . . . . 112
Chapter 6

Biological Dimensions of Forest Planning

INVENTORY AND MONITORING

IN A STRATEGIC PLAN

Strategic planning requires systematic monitoring

of resources to assess trends and manage according

to public desires. An inventory of resources is

necessary to provide baseline data on what exists on

the forests. Monitoring leads to a continuous record

of information on the quality and quantity of

resources and permits an evaluation of trends.

Monitoring activities can be adjusted to respond to

trends, changing interests, and emerging issues.

The Forest and Rangeland Renewable Resources

Planning Act of 1976 (RPA) and the National Forest

Management Act of 1976 (NFMA) call for an

integrated approach to resource management:

In the development and maintenance of land

management plans . , . the Secretary shall use a

systematic interdisciplinary approach to achieve

integrated consideration of physical, biological,

economic, and other sciences (section 6(b)).

The integrated approach was to minimize duplication of data gathering and to facilitate considering

interactions among resources in developing forest

plans (174). Some researchers consider inventories

aimed at collecting data on one resource, such as a

timber survey, to be multiresource inventories,

because some of the collected information might be

useful to an analysis of other resources, such as

wildlife habitat. Lund (156), however, limits multiresource inventories to those with planned integration. He defines an integrated inventory system with

six characteristics: 1) adaptable to a wide range of

ecological conditions; 2) easy to use at different

levels of management; 3) replicable and suitable for

statistical analyses; 4) flexible enough to fulfill

different information needs; 5) adaptable to a

monitoring program; and 6) suitable for use with

automated data processing. An integrated resource

inventory also includes a multiresource component

that emphasizes interactions among variables (174).

Because planning under NFMA calls for an

integrated approach to resource management, the

Forest Service must structure inventory and monitoring programs around integrated multiresource

characteristics. This is not an easy task. An inventory and monitoring system that exhibits integrated

multiresource characteristics will result, by its very

design, in compromises in the gathering and analysis

of data (174). For example, rangelands are defined

by several physical features (topography and soil

conditions) as well as a suitability factor for grazing

by domestic livestock or wildlife. To inventory and

monitor adequately the range-forage resource, the

Forest Service must make specific decisions regarding which elements or combination of elements

(interactions) to address, including specific methods

of inventory, data analysis, and model development

(174). The many decisions required to define the

resource characteristics and ensure an integrated

design make it extremely difficult to strive for an

integrated multiresource inventory and monitoring

program.

RESOURCE INVENTOR Y

AND MONITORING I N

THE FOREST PLAN S

1

Inventory and monitoring require the collection of

information. When data collection is planned efficiently, inventory information can also be used in

monitoring, and monitoring can be used to update

and improve inventories (137). The primary difference between the two activities is that inventories

are used to guide plan development, while monitoring is used to measure plan implementation and

effects. An inventory might include collecting data

on sizes and types of trees, or number of eagle nests

with young. Monitoring would then include maintaining the records of tree size and type, or number

of eggs hatched over time, to permit a determination

of trends-in annual growth rates or hatching

success. Both resource inventory and monitoring are

essential 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 plans

were 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 illustrate

problems that are inherent in many of the plans.

–lo9–
110 ● Forest Service Planning: Accommodating Uses, Producing Outputs, and Sustaining Ecosystems

the national forests and to the proper implementation

of management activities.

Since NFMA was enacted and the regulations

have been in effect, several problems have surfaced

in relation to inventory and monitoring activities

conducted by the Forest Service. Problems common

to both inventory and monitoring are discussed

below. Problems unique to data gathering or to

monitoring programs are then addressed in separate

sections.

Forest inventory and monitoring have been criticized for failing to produce an integrated, multiresource program. The scientific community, which

has participated in long-term discussions on what

constitutes appropriate inventory and monitoring, is

as much to blame for this failure as the Forest

Service (174). Although there is general agreement

on the need for rigorous application of proper

sampling design and statistical analyses, ‘‘few clear

guides exist in the scientific literature on how

specific resources should be inventoried and monitored” (174). Advanced academic training and

extensive research experience are required to design

inventories, analyze inventory data, and establish

monitoring programs that will achieve an appropriate standard. The scientific community, however,

has not agreed on the makeup of a “rigorous and

proper’ sampling design. And, the Forest Service

has not been quick to institute an integrated multiresource program, because specific designs and

analytical techniques have not been established, and

because the agency has not had enough experts to

design such programs.

Slowness in developing an integrated multiresource inventory and monitoring system also can

be blamed on the Forest Service’s historical emphasis on inventory of the timber resource. Before

passage of RPA and NFMA, inventorying by the

agency concentrated primarily on ways to maximize

timber production (162, 174). Inventory and monitoring programs used by the Forest Service today

attempt to include integrated, multiresource inventories but are designed largely by retrofitting timberoriented programs (174).

Even in 1986, in the absence of final Forest Plans,

functional timber management plans were still

prepared and were still the basis of most day-to-day

management activities (122).

Retrofitting a timber-focused program to include

integrated, multiresource inventories has persisted

in forest planning for three reasons. First, agency

personnel have training and experience in specific

techniques and are slow to change (174). Second,

substantial changes in sampling design may impede

the use of previously collected data. Finally, the

original version of FORPLAN, the primary forest

planning model, was not designed to address forest

multiresource interactions. (See also ch. 7.)

Another shortcoming of forest inventory and

monitoring programs has been the failure to address

ecosystem processes, and the lack of attention to

appropriate spatial and temporal scales for examining ecosystems. The enormous complexities of

nature-soil formation, plant growth and succession, decomposition by fungi and bacteria, modifications by invertebrates and vertebrates, and natural

catastrophes, especially forest frees-should be accounted for in an inventory and monitoring program

(174). In the past, many ongoing resource inventories were designed to furnish information about the

condition of a single resource for a small land area,

such as a timber sale or a report on range or

watershed improvement needs (166). In contrast,

inventory data for a forest plan must provide

information on a forestwide basis, often a million

acres or more, for decisions that need to be made in

the planning process. An inventory of timber stands

does not address ecosystem elements. Aggregation

of timber stands into larger units will also not

address interactions that go beyond the stand boundaries, such as water flows and wildlife movements.

In addition, appropriate temporal scale must be

adopted for evaluating ecological systems. For

example, sampling wildlife in only one season (e.g.,

summer only or winter only) will bias data collection

to breeding or wintering requirements. Data for a

forest plan must, therefore, be collected at the

appropriate scale (in time and space) and be more

organized-by resource as well as by site, date of

information, and possible interrelated effects-than

data collected under a nonintegrated approach for

small areas (166)0

Data collection and monitoring by the Forest

Service has also been criticized for not being

sensitive to statistical requirements for effective data

analysis. Critics have pointed to several key components for statistical evaluation of data: clear identification of variables to be evaluated; accuracy and

precision of variable estimates; and adequacy of
Chapter 6--Biological Dimensions of Forest Planning ● 111

sample sizes (174). The weaknesses in statistical

validity of Forest Service inventories and monitoring have been attributed to the lack of biometricians

on the planning teams. 2 This lack of expertise has

resulted in the inability to improve data collection

and analysis for accurate reporting of resource

conditions and trends (174).

Problems with inventory and monitoring activities of the Forest Service are made worse by the lack

of adequate funding (166). Monitoring is expensive

and funding has not been provided for the systematic

completion of forestwide inventories for most resources. For example, range managers on a national

forest may use a variety of range inventories.

Analysis of some allotments may have been completed recently and include field measurement of

forage use. Other allotments may have been inventoried many years ago, using different inventory

techniques. Some allotments may never have been

inventoried (166).

Verner (304) provided a worst case scenario in

response to the question, ‘‘Can we afford reliable

monitoring systems?” He used the pileated woodpecker (Dryocopus pileatus) to illustrate that the

cost of monitoring annual changes in abundance on

a particular forest for this species could exceed $1

million per year. The potentially high costs of

monitoring activities, and the lack of adequate

funding, require managers to analyze costs carefully

as the monitoring plans are being developed.

RESOURCE INVENTORY

Inventory Requirements in NFMA

and 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 base

the forest plans on those inventories (section 6(f)(3)).

NFMA contains several planning requirements that

imply the need for resource inventories. For example, plans are required to provide ‘sustained yield of

products and services” (section 6(e)(l)) by generally limiting timber harvests to ‘‘a quantity which

can be removed . . . annually in perpetuity’ (section

13(a)). To meet this requirement, a national forest

must have inventory information on the stocks and

growth rates of its trees.

Other planning requirements that depend on data

from resource inventories are associated with land

capabilities. Plans are required to ensure that timber

is harvested only under certain conditions: lands that

are suited for timber production considering physical, economic, and other pertinent factors (section

6(k)); lands where adequate reforestation can be

assured within 5 years after harvest (section 6(g)(3)

(E)(ii)); and lands where soil, slope, or other

watershed conditions will not be irreversibly damaged (section 6(g)(3)(E)(i)). In developing the timber program, the forest must provide for the protection of water bodies ‘‘where harvests are likely to

seriously and adversely affect water conditions or

fish habitat” (section 6(g)(3) (E)(iii)). Plans must

also provide for the diversity of plant and animal

communities based on the suitability and capability

of the specific land area (section 6(g)(3)(B)). NFMA

also requires the plans to be revised when conditions

have significantly changed. Again, developing and

maintaining resource inventories can facilitate fulfilling these requirements.

NFMA’s requirements for resource inventories

are reiterated and expanded in the regulations

governing forest planning issued by the Forest

Service in 1979 and revised in 1982:

Each Forest Supervisor shall obtain and keep

current inventory data appropriate for planning and

managing the resources under his or her administrative jurisdiction. The Supervisor will assure that the

interdisciplinary team has access to the best available data. This may require that special inventories

or studies be prepared. The interdisciplinary team

shall collect, assemble, and use data, maps, graphic

material, and explanatory aids, of a kind, character,

and quality, and to the detail appropriate for the

management decisions to be made. Data and information needs may vary as planning problems

develop from identification of public issues, management concerns, and resources use and development opportunities. Data shall be stored for ready

retrieval and comparison and periodically shall be

evaluated for accuracy and effectiveness (36 CFR

219.12 (d)).

The regulations require: specific inventories of

roadless 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).
112 . Forest Service Planning: Accommodating Uses, Producing Outputs, and Sustaining Ecosystems

populations (36 CFR 219.19); forage production and

range conditions (36 CFR 219.20(a)); recreation

opportunities (36 CFR 219.21 (a)(l-3)); visual resources (36 CFR 219.21(f)); water and watershed

conditions (36 CFR 219.23 (a),(b), (c),and (e)); cultural and historic resources (36 CFR 219.24(a)

(l-6)); unique biological and geologic areas (36 CFR

219.25); and diversity of plant and animal communities (36 CFR 219.26). Like NFMA, the regulations

contain several planning requirements that imply the

need for resource inventories: determination of

maximum physical and biological production potentials (36 CFR 219.12 (em)); land suitability and

assurance of reforestation for timber production (36

CFR 219.14 (a)(l-4)); culmination of mean annual

increment of growth of timber species (36 CFR

219.16 (a)(2) (iii)); and sustained yield of timber

harvests (36 CFR 219.16(a)(2)(iv)).

Problems With Inventory Data

Although NFMA and the implementing regulations require national forests to base initial and

subsequent planning efforts on resource inventories,

direction is not provided on how ongoing inventories should be used in planning (137, 238). Some

plans refer to inventories in their goals and objectives and monitoring plans, or even include inventory activities as a subcategory in each resource

section of their standards and guidelines. Other plans

may contain little or no reference to resource

inventories, or may list only new inventories that

would be required for plan implementation.

A report by the Committee of Scientists reviewing

proposed NFMA regulations considered adequate

inventory data essential to sound forest plans:

No plan is better than the resource inventory data

that support it. Each forest plan should be based on

sound, detailed inventories of soils, vegetation,

water resources, wildlife, and the other resources to

be managed (48).

Despite the critical role of good inventory data, the

committee found that data for most resources in the

plans were insufficient for making management

decisions.

Nonetheless, the Forest Service has made progress in developing inventories in the 15 years since

NFMA was enacted. A current agency handbook

provides guidance on resource inventories, and

identifies five objectives for Forest Service inventories: 1) determine the condition, production, potential, and amounts of key ecosystem components or

processes; 2) identify a benchmark for describing the

current physical and biological situation and for

forecasting projected changes; 3) provide ecological

information as a basis for protection and management decisions about land and resource uses, proposed plans, or actions; 4) consider conditions and

trends that either change the demand for resources or

that are affected by resource decisions; and 5) refer

all inventory information to specific units of land

(284).

These general objectives, however, have not

ensured that forest planning will address past

problems with inventories, such as gaps in information on plants and nongame and invertebrate animals

(174, 238, 321). For example, of eight forests

examined, only the Eldorado National Forest identified inventories used in initial plan development

(137). (See table 6-l.) Even in this case, the data and

methods used to conduct the inventories were not

identified. Major problems with inventories on the

national forests are discussed below in relation to

quantity, quality, and timeliness of inventory data,

and compliance with NFMA requirements.

Table 6-1--National Forest Plans Sampled for Inventory and Monitoring Reviews

Draft Final

Forest Region State plan plan

Bitterroot . . . . . . . . . . . . . . . . . . . .

San Juan . . . . . . . . . . . . . . . . . . .

Coconino . . . . . . . . . . . . . . . . . . .

Dixie . . . . . . . . . . . . . . . . . . . . . . .

Eldorado . . . . . . . . . . . . . . . . . . . .

Siskiyou . . . . . . . . . . . . . . . . . . . .

Nantahala and Pisgah . . . . . . . .

Nicolet . . . . . . . . . . . . . . . . . . . . . .

1

2

3

4

5

6

8

9

Montana

Colorado

New Mexico

Utah

California

Oregon

North Carolina

Wisconsin

1985

1982

1985

1985

1986

1987

1984

1984

1987

1983

1987

1986

1989

1989

1987

1986

SOURCE: L. Krahl, H. Swertson, and H.H. Carey, The hnpads of NfM4 on Resource /inventories andknitotig on

the 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 many

forests. Some timber inventories have been based

primarily on air photo interpretation. Critics claim

they contain little information on growth rates and

location of stands, little field reconnaissance, errors

in classification of plots, and questionable acreage

figures (42). For example, the Cibola National

Forest defined and mapped areas based on soil

characteristics, potential natural vegetation (PNV),

and slope (166). Field data were used for 20 percent

of the forest, while the remaining 80 percent was

delineated using aerial photos, limited site examination, and extrapolation from existing inventories.

Thus, field measurements required for accurate and

replicable location of unit boundaries were available

for only a small number of areas. Accuracy and

replicability could have been improved if more time

and funding had been available. Improvements in

the next planning cycle are likely because of more

extensive survey work being completed on this

forest (166).

In other cases, timber data may be inadequate

because timber plots from early inventories may not

be remeasured to verify growth rates (42). Growth

rates for timber stands may simply be predicted by

computer programs without field verification (42).

Forests also may be classified by site productivity

classes rather than present vegetation—a misleading

classification system for designating timber stand

suitability (42).

As with other resources, inventories on soils and

rangeland resources vary in quality and quantity.

Some national forests have designed their soil

inventories to provide information over large land

areas quickly and have relied on air photo interpretation with limited field reconnaissance. Inventories

designed in this way require supplemental information for use in high intensity or small area planning

projects (42). For example, the Idaho Panhandle

National Forests grouped all soils information into

four categories (sensitive or nonsensitive soils with

slopes over or under 40 percent). The environmental

impact statement noted that a greater number of

‘‘specific land types would provide more accurate

response units, ’ but that FORPLAN was incapable

of handling more types.

Variations in range resource inventories are explained by lack of funding as well as amount of

rangeland present on the forest, and thus the priority

in forest inventory tasks (166). For example, only a

small portion of the Idaho Panhandle forests—about

7500 acres—is managed for domestic grazing (42).

The range inventory for these forests, as described in

the forest plan, is designed to provide useful

information about the range resources. However, the

descriptions of range allotments were labeled as

“vague and subjective’ (42).

Likewise, the Forest Service has described data on

range condition on the Cibola National Forest as

‘‘available but inadequate’ and has criticized past

data collection strategies for being based on reports

that ‘‘went back several decades and are not

consistent with present methodologies” (166, 270).

Data quality in the Cibola forest plan generally

has been poor (166). The Cibola forest planners

stated that it is not Forest Service policy to do

resource inventories specifically for land management planning. Rather, the forest relies on compiling

a database for the plans by extrapolating and

disaggregating data collected for other management

purposes. The forest is, however, now developing

two data sets based on field inventories. One, for

timber, examines all commercial timber stands. The

second is a terrestrial ecosystem survey examining

soil characteristics, potential natural vegetation, and

slope. The forest is also working on implementing a

geographic information system in anticipation of

markedly improved data.

Timeliness of Inventory Data

Delays in forest plan completion may lead to as

much as a 10- to 15-year gap between the date the

data were collected and publication of the plan

(137). Six of the forests in table 6-1 used timber

inventories that were at least 5 years old when the

draft plans were released. The timber inventory was

up to 8 years old in the draft plan for the Siskiyou and

15 years old in the draft plan for the San Juan.

Additional problems exist with respect to timeliness of data collection. Forest Service planning rules

adopted in 1979 stated that”. . . existing data will be

used in planning unless such data is [sic] inadequate” (36 CFR 219.5). Forest Service Manual

provisions issued in March 1980 added to this rule:

Where additional data and information collection

is necessary, it must be limited to that which is

essential for analysis and decisionmaking in the

planning process (267).
114 . Forest Service Planning: Accommodating Uses, Producing Outputs, and Sustaining Ecosystems

Under direction of the Chief of the Forest Service to

rely substantially on existing data, some forests

postponed new inventories, and used existing data

that were not comprehensive enough to aid planning

and management decisions (42). Although the 1982

revision of the forest planning rules eliminated the

statement that “existing data will be used,” by that

time, some forests were committed to using existing

data in preparing their plans (42).

Compliance With Inventory Requirements

Several plans from forests in table 6-1 failed to

comply with inventory requirements in NFMA. One

of the critical requirements is the inventory of

roadless areas. Only one (the Bitterroot) provided for

an annual inventory of roadless areas and changes in

wilderness characteristics. Staff on the other forests

stated that, although they did not have systematic

inventories of wilderness characteristics in roadless

areas, they did include assessments of these characteristics in the National Environmental Policy Act

(NEPA) documentation for proposed projects in the

wilderness areas (137). The forest staff stated that

the inventory conducted under the second roadless

area review and evaluation (RARE II) was sufficient, and that project-specific assessments were

adequate to maintain the inventory (137).

The sufficiency of the RARE II inventories has

been questioned, however. In California v. Block

(690 F. 2d 753, 9th Cir. 1982), the court held that

RARE II failed to meet the NEPA requirements for

site-specific evaluation of the consequences of

recommending that areas be available for nonwilderness management. This ruling required forest

planners to reevaluate RARE II roadless areas for

wilderness. For the Idaho Panhandle National Forests, the Forest Service stated that the analysis of

roadless areas had a substantial effect on the

outcome of the plan (282). However, one critic

claimed that the analysis had little effect on the

forest plan because many distinguishing attributes of

the forests’ roadless areas were not identified in

FORPLAN (42).

Only two of the plans from the eight forests in

table 6-1 (Siskiyou and Coconino) prescribed inventories for threatened fish habitats, and none identified inventories of waters threatened by timber

harvests (137). Interviews with forest staff suggested that, although the inventories were not

prescribed in the plans, conditions of aquatic resources are inventoried, especially within project

areas.

Summary and Conclusion

The poor quality of national forest resource

inventories, the lack of coordination among various

resource-specific inventories, and the inappropriate

use of information in decisionmaking contributed to

the enactment of NFMA (137). The situation on the

forests since NFMA was enacted has not changed

substantially. Absence of data along with poor data

quality, limited collection of new data, out-of-date

information, and failure to comply with the law are

inherent in many of the resource inventories of the

forest plans. These problems are magnified by data

that are poorly documented and inaccessible. Some

forests have not set up a well-organized, easy-toaccess data system that the public could use to obtain

background information on resource inventory or

even to know what inventories are maintained. Few

forests summarize their resource inventories in a

document that is appropriate for reading by the

general public (238).

A critical first step in the planning process is to

identify key resource management decisions and

define data needs. The Forest Service, in trying to

make management decisions based on limited data,

must examine available knowledge, combine it with

expert opinion, and make predictions about the

consequences of alternative management actions

(247). While the national forests rarely have all the

information that might be desirable to make a

management decision, and certainly are in need of

more and better data to assist in management

decisions, it is important that the existing data are

accessible and applied to appropriate management

situations. Major roadblocks-an emphasis on timber inventory as well as little funding-have limited

the scope of resource inventories. Priorities can be

set by identifying significant gaps in resource data.

New inventories can be designed to provide missing

information, with special and unusual data needs

met with additional surveys and inventories. Inventory data that do exist must provide baseline

information for identifying and examining impacts

of activities conducted on the forests. The inventory

data must be organized and presented in a meaningful, usable form that can be aggregated for a broader

picture of the Nation’s resources.
Chapter 6--Biological Dimensions of Forest Planning ● 115

RESOURCE MONITORING

Monitoring Requirements in NFMA

and the Regulations4

In contrast to its inventory requirements, NFMA

contains no general provision requiring monitoring.

The word ‘‘monitoring’ appears only once, in

reference to research and evaluation of the effects of

management systems (section 6(g)(3)(C)). The need

for monitoring is inferred in requirements for

reforestation (section 3(d)(l)), herbicide and pesticide use (section 3(e)), revegetation of temporary

roads (section IO(b)), and implementation of evenaged harvest (section 6(g)(3)(f)(v)).

Unlike the law, the regulations highlight monitoring as a critical component of forest planning. The

regulations require monitoring plans as part of the

land and resource management plan for each national forest. Implementation of these monitoring

plans must be reviewed periodically to determine if

the prescribed monitoring is occurring as well as if

the resources are being managed sustainably.

At intervals established in the plan, implementation shall be evaluated on a sample basis to

determine how well objectives have been met and

how closely management standards and guidelines

have been applied. Based upon this evaluation, the

interdisciplinary team shall recommend to the Forest

Supervisor such changes in management direction,

revisions, or amendments to the forest plan as are

deemed necessary (36 CFR 219.12(k)).

Additionally, the regulations imply that monitoring must be conducted to assess the impact of timber

harvests on soil, water, fish, wildlife, recreation, and

aesthetic resources (36 CFR 2 19.27(c)(6)). Monitoring to preserve and enhance the diversity of plant

and animal communities is also implied in regulatory requirements for diversity ‘‘at least as great as

that which would be expected in a natural forest”

(36 CFR 219.27(g)). The regulations require that

monitoring include: quantitative outputs and services and costs of management prescriptions (36 CFR

219.12 (k)(l)and(3)); documentation of measured

prescriptions and effects, including significant changes

in productivity of the land (36 CFR 219.12(k)(2));

and a description of actions, effects, or resources

measured, the frequency of measurements, the

expected precision and reliability of the monitoring

process, and the time when evaluation will be

reported (36 CFR 219.12 (k)(4) (i-iii)).

The monitoring requirements in NFMA and the

regulations reinforced some existing Forest Service

activities. Measuring and reporting outputs and

monitoring project implementation had been conducted on the national forests for many years.

NFMA and the regulations augmented these procedures by requiring the forests to: 1) specify standards

and guidelines for monitoring project implementation; and 2) monitor environmental impacts, a

practice that had not been common, especially for

noncommodity resources. NFMA also requires that

forest plans be revised when conditions have

changed significantly, but at least every 15 years

(section 6(f)(5)(A)). This implicitly requires that

forest plan implementation and forest conditions be

monitored, to determine when significant changes

have occurred. The regulations further require forest

supervisors to “review the conditions on the land

covered by the plan at least every 5 years to determine whether conditions or demands of the public

have changed significantly” (36 CFR 219.10(g)). If

the supervisor finds significant changes, the plan

must be revised.

Problems With Monitoring Activities

Compliance With Monitoring Requirements

Monitoring measures the results of resource

management activities to ensure that prescribed

activities are undertaken and that they have the

expected effects. The regulatory requirements for

reports 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 Bitterroot

has issued annual monitoring reports according to

the schedule in its plan (137). The Dixie completed

its plan in 1986 and the Eldorado and Siskiyou

completed their plans in 1989. These forests may

release monitoring reports by the end of 1991.

Although all of the plans in table 6-1 prescribed

monitoring activities to measure product and service

outputs, they were less consistent in prescribing

monitoring to assess noncommodity resources (137).

Only two plans (Dixie and Siskiyou) prescribed

monitoring to meet all of the noncommodity goals

and objectives in their forest plans. Three plans

4B~ hgely on Krahl et al. 1990 (137).
116 . Forest Service Planning: Accommodating Uses, Producing Outputs, and Sustaining Ecosystems

(Bitterroot, Coconino, and the Nantahala/Pisgah)

prescribed monitoring for at least 75 percent of their

noncommodity goals and objectives, while the

remaining three plans (Eldorado, Nicolet and San

Juan) prescribed monitoring for less than 65 percent

of their noncommodity goals and objectives (137).

In addition, despite the requirement to submit an

annual report on the amounts, types, uses, and

beneficial or adverse effects of herbicides and

pesticides, none of the eight plans in table 6-1

included this information. Even though this information was not in the plans, staff from these forests

stated that they report herbicide and pesticide use, in

compliance with regional or State requirements

(137).

Levels of Monitoring

The Forest Service defines monitoring at three

different levels: 1) implementation monitoring, or an

evaluation of whether management activities are

carried out according to the forest plan; 2) effectiveness monitoring, or an evaluation of whether the

management activities meet the plan objectives; and

3) validation monitoring, or an evaluation of whether

the initial plan assumptions are correct (267). (See

box 6-A.) To date, complaints with implementation

monitoring have been the most common, but problems with all three levels of monitoring have led to

criticism of the management plans.

Implementation monitoring poses the question:

“Did the Forest Service do what they said they

would do?’ Many monitoring programs have been

criticized for promising too much (42, 248). For

example, personnel needs in the Chequamegon

National Forest’s monitoring plan for the next 6

years (1990 to 1996) call for an increase of 95

percent in the number of work days over that of

1989—an unlikely scenario (238). As implied in the

plan, however, the proposed increase would considerably enlarge the scope of the monitoring program

and provide the forest with greater knowledge of the

condition of its resources.5

The Idaho Panhandle monitoring plan has been

criticized for uneven monitoring-items that are

easy to quantify, like the size of timber cutting units,

were successfully monitored, while items less easily

quantified, e.g., wildlife and fish population trends,

were less successfully monitored. Some items were

Box 6-A—Example of Levels of Monitoring

on a National Forestl

Forest Plan Goal: To maintain stream temperature by keeping 10 percent of Moose Creek in shade

and thereby maintain trout populations in Moose

Creek.

Forest Plan Standard and Guideline: Do not

remove any trees within 15 feet of a stream.

Implementation Monitoring: Did the forest do

what they said they would do? Did the forest

remove any trees within 15 feet of the stream?

Effectiveness Monitoring: Did the Forest Service

accomplish what they set out to do, and did they do

it in the most efficient way? Can the trout populations in Moose Creek be maintained by not

removing any trees within 15 feet of the stream?

Validation Monitoring: Are the Forest Service

goals and objectives appropriate? Does maintaining

10 percent of Moose Creek in the shade keep

temperatures from rising above the limit for maintaining trout populations?

l~o~on~t~ from-out 11.13, Unit 11, Monitoring and Evaluation of the Forest Plan Implementation Course

19(B01.

not monitored at all (e.g., the status of certain

wildlife species and effects of management on

insects and disease) (42).

Effectiveness monitoring poses the question:

“Did the Forest Service accomplish what they set

out to do, and did they do it in the most efficient

way?” The forest plans have been criticized for

inaccurate reporting of resource conditions. An audit

by the Idaho State Department of Lands found that

some timber sales on the Idaho Panhandle had

unacceptable implementation of best management

practices (BMPs). In 1989, the forest began a

program to determine if the BMPs were successful

in meeting State water quality requirements. At least

four of the planned watershed monitoring programs

were not completed due to lack of funding and

personnel (42).

Validation monitoring poses the question: “Are

the Forest Service goals and objectives appropriate?” Regardless of specific monitoring programs

developed 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 fiscal

year 1988 to over $50,000 in fiscal year 1991 (letter from Forest Service to OTA, Aug. 20, 1991).
Chapter 6--Biological Dimensions of Forest Planning ● 117

be defendable in terms of rigorous study design and

analysis (174). If, as is often the case, the forests

have not carried out the proposed monitoring

activities it is difficult to evaluate this question.

Thus, investigations of Forest Service monitoring

cannot evaluate the appropriateness of Forest Service goals and objectives because there are few data

to analyze and defend.

Summary and Conclusion

Monitoring on the national forests involves the

repeated inventory of managed resources to determine conditions and trends. Because the Forest

Service is directed to maintain a comprehensive

survey and analysis of conditions of renewable

resources under its jurisdiction (section 3(b)), the

focus of this section of the law is really monitoring

rather than point-in-time inventory (174). It is still

early to determine whether the Forest Service has

successfully met its monitoring requirements—

some of the forests have not yet issued monitoring

reports. The monitoring the Forest Service has

scheduled, however, often has not been implemented. The forests have typically promised more

than they have been able to deliver.

One way of reducing measures of ecosystem

health to a manageable level is to review the

relevance of the chosen measures to human concerns

(127). Important characteristics to include in an

inventory and monitoring program relate directly or

indirectly to something that people are concerned

about. Identifying these characteristics may require

an explanation of why the measure is relevant.

Newly proposed regulations (287) may strengthen

the role of monitoring in the planning process. The

agency may place renewed emphasis on integrated,

multiresource programs and an ecosystems approach. Given the lack of money for detailed

monitoring, however, the forests need to reevaluate

their monitoring plans. The plans must reflect more

accurately what is possible and what is most

important to accomplish under staff and budget

constraints and according to public interest.

SPECIAL ISSUES

Biological Modeling

Environmental planning requirements of NFMA

are varied and extensive. In fact, the data required

from the Forest Service by law ‘are far beyond those

ever compiled by the Forest Service or anyone else

. . . “ (51) Historically, most forests have lacked

data useful to forest planning, including reliable data

on tree growth and yield (particularly for regenerated stands in plantations) and up-to-date vegetation

maps (64). Forestry research also had not provided

much support in the way of practical biological

models for forest planning (64). After NFMA, the

overwhelming task facing forest planners was to

come up with reliable, desirable plans for large,

complex, million-acre areas-a task requiring a lot

of data, time, money, and a skilled workforce. Not

enough of any of this was provided to the agency to

accomplish the tasks required in NFMA (64).

As abstractions and simplifications of reality,

biological models depict relationships among environmental factors (174). Models represent a theoretical framework for understanding the environment.

Simplification is necessary in model development,

to describe complex systems in comprehensible

ways. The extent and form of the simplification are

critical, because if the simplification is not appropriate, management decisions based on the model will

be faulty (174). Inappropriate simplification of

models has resulted from poor quality data, data that

emphasize the timber resource, and failure to recognize the importance of scale in study design.

Data Problems

Despite RPA/NFMA requirements for integrated,

multiresource inventories, Forest Service inventory

and monitoring have failed to support models

depicting resource interplay within a complex environment (174). The historic emphasis on timber in

Forest Service management has led to inventory data

that fit into models for timber production forecasting. Forest models developed for FORPLAN emphasize the growth, manipulation, and harvest of

trees (64). (See also ch. 7.) FORPLAN’s emphasis

on timber management reflects both the design of

FORPLAN and the lack of reliable theory and data

to quantify nontree outputs. Except for timber

assessments, “Land managers have had to rely on

intuitive judgment rather than the evaluation of

systematically organized data sets and processes’

(135). FORPLAN directly or indirectly links outputs

such as forage, water, sediment, recreation, fish,

visual quality, and wildlife habitat to forest management through land allocations and restrictions on

timber production (64). For example, FORPLAN

rarely contains a reliable, well-documented, quanti-
118 . Forest Service Planning: Accommodating Uses, Producing Outputs, and Sustaining Ecosystems

tative yield table to represent nontimber outputs and

how they respond to use and development. In many

cases, the existing inventories emphasizing timber

are now driving model development, rather than the

models driving data collection by generating hypotheses that determine critical variables and appropriate sampling designs (174).

Wildlife managers are especially challenged to

provide sufficient and reliable data on nongame

species, which are essentially new to the inventory

(304). Models have been developed to estimate

effects of forestry activities on these species and to

forecast trends in abundance. However, many wildlife population models have been developed on

assumptions about habitat suitability that may not be

valid (304). For example, one common assumption

is that species abundance can be used as an index to

habitat suitability. Challenges to this assumption

suggest that indices based on demographic parameters (e.g., clutch size or growth rate) may prove to be

more reliable than indices based on abundance (96,

302). Another common assumption in wildlife

population models is that populations change in

proportion to the availability of suitable habitat

(304). However, animal numbers may beheld below

carrying capacity by other factors, including predation, parasitism, competition, weather extremes, and

unpredictable events.

Even if wildlife population models are correct in

assuming that abundance may be a good measure of

habitat suitability, critics claim that the available

data are still insufficient to draw conclusions for

guiding management activities (304):

Existing inventory techniques are generally too

expensive and they require more skilled personnel

than are available . . . To date, no comprehensive

system for monitoring wildlife resources on a major

land-management unit has been developed and

tested . . .

Questions have also been raised regarding logistical

procedures for updating files that are used to build

biological models. Verner (304) claimed that efforts

to update inventories on national forests “have been

marginally successful because of cost and lack of

suitable computerized data files."

Scale Problems

Use of appropriate scale is also a problem in the

modeling of biological systems for the national

forests. The characteristics of ecological systems

differ at different scales. For example, small plots

surveyed for bird species may show that two species

are found in different habitats, perhaps in forests of

different age classes. When surveying at a broader

scale, the two species may be associated together

rather than with other species that occur in more

distinct habitats, such as cattail marshes or sedge

meadows. Thus, inventory results would vary depending on the scale of survey.

[I]f we study a system at an inappropriate scale,

we may not detect its actual dynamics and patterns

but may instead identify patterns that are artifacts of

scale (319).

Each forest is unique at the continental scale,

since major environmental factors such as geologic

features, temperature, and precipitation vary throughout the country (172). Each forest is also unique,

however, at the local level, where topography,

geology, and history influence conditions. It is

important that management decisions recognize the

appropriate scale of influence and impact of management activities. Section 6(b) of NFMA requires

that a systematic interdisciplinary approach, including economic and environmental considerations, be

used to evaluate management alternatives. This

implies that the plans will show interactions among

the managed resources. Shugart and Gilbert (234)

conclude that:

One might argue that the Forest Service should

not be trying to do such comprehensive planning

forest-wide, and yet the National Forest Management Act states that a single plan must be produced.

One approach to improve the usefulness of

biological models in forest planning is to treat

models as tools rather than goals:

The goal is to apply research findings usefully to

predict management effects. . . The model is but one

tool to reach the goal (36),

Management is, in many respects, an experiment in

applying models to the real world. Results are

monitored to evaluate and improve the models

(146). Development of multiple-resource models

with linkages to a geographic information system

are described as particularly promising for integrated analysis at various scales (146). GIS can

provide information on resources with site specificity in an accessible format and assist in the evaluation of results from the models and in the estimations

of environmental effects (278).
Chapter 6--Biological Dimensions of Forest Planning ● 119

Biological Diversity

Legal Requirements

Biological diversity refers to the variety and

relative frequency of living organisms (174). Ecosystem interactions are integral components of

biological diversity, and biological diversity, in turn,

determines ecosystem interactions. Morrison (174)

offered the following analogy for understanding the

relationship between biodiversity (biological components of the ecosystem) and ecosystem functioning:

You can count all the parts of a vehicle and assess

their condition individually without being assured

that the assembled vehicle will start, or how well it

will run over the long term. The fewer parts you

inventory and monitor, the less likely you will be to

predict whether the finished product is complete and

how it will function.

NFMA directly refers to maintaining biological

diversity in the land and resource management

plans. Section 6(g)(3)(B) states that the regulations

for developing the plans are to:

. . . provide for diversity of plant and animal

communities based on the suitability and capability

of the specific land area in order to meet overall

multiple-use objectives . . .

The Committee of Scientists interpreted this as

clear congressional intent for considering diversity

throughout the planning process and for maintaining

or increasing the diversity of plant and animal

species and of biological communities (48).

The Forest Service regulations repeat and expand

on NFMA’s guidance to provide for diversity of

plant and animal communities in the forest plans:

Forest planning shall provide for diversity of plant

and animal communities and tree species consistent

with the overall multiple-use objectives of the

planning area. Such diversity shall be considered

throughout the planning process. Inventories shall

include quantitative data making possible the evaluation of diversity in terms of its prior and present

condition. For each planning alternative, the interdisciplinary team shall consider how diversity will

be affected by various mixes of resource outputs and

uses, including proposed management practices (36

CFR 219.26).

The regulations also limit the loss of diversity to

be tolerated under prescribed management practices

(36 CFR 219.27(g)) and recognize that national

forests are ecosystems and that their management

requires awareness of the interrelationships among

resources (36 CFR 219.1(b)(3)). The regulations

specify biological diversity as a criterion for evaluating lands as potential wilderness areas (36 CFR

219.17(a)(2)(v)).

In addition to the requirement to inventory and

monitor the diversity of plant and animal communities, Forest Service regulations require the forests to

maintain viable populations of species:

Fish and wildlife habitat shall be managed to

maintain viable populations of existing native and

desired non-native vertebrate species in the planning

area (36 CFR 219.90).

A viable population is defined as ‘one which has the

estimated numbers and distribution of reproductive

individuals to insure its continued existence is well

distributed in the planning area” (36 CFR 219.9). A

Department of Agriculture regulating extends the

requirement beyond vertebrates, to maintain at least

viable populations of “all existing native and

desired non-native plants, fish, and wildlife species” (321). Population viability is one part of

biodiversity, since diversity clearly declines when

species go extinct (174). Thus, inventory and

monitoring for diversity must estimate the numbers

of organisms as well as assess the relationship

between the numbers and population viability (174).

Wilcove (321) argued that forest plans have failed

to address the issue of conservation of biological

diversity adequately. The current approach tends to

increase populations of widespread species at the

expense of rarer species, because each national

forest can assure viable populations for common

species but not for uncommon species. In contrast,

a regional approach considering all landowners

could better fulfill the intent of preserving biological

diversity in all natural ecosystems (321).

The inadequate treatment of biological diversity

has been blamed, at least in part, on the failure to

identify measurable attributes of diversity for inventory and monitoring programs (184). Ness (184)

outlined a characterization of biodiversity that

identified three biological components--composiSUS, Dwmment of Agl-icu]~e, Dep~mental Regulation 9500-4, Fish and Wildlife policy, Aug. 22+ 19~3
120 . Forest Service Planning: Accommodating Uses, Producing Outputs, and Sustaining Ecosystems

tion, structure, and function--for four levels of

diversity-regional, community, population, and

genetic. Others have also called for conservation of

biological diversity using a more comprehensive,

landscape-level approach (107, 318).

Diversity in NFMA Planning

Although NFMA requires the national forests to

inventory diversity, neither the law nor the regulations specify the kinds of data needed to create such

inventories. Forest plans, therefore, vary in the data

they consider in their evaluation of diversity (238).

A review of 20 national forest plans showed that

most of the forests specified the level of diversity,

stated the diversity level in terms of overall multipleuse objectives, discussed the consequences of the

diversity level provided, and justified the reductions

in existing diversity in terms of multiple-use objectives (167). Management prescriptions to provide

for diversity of the natural forest, however, were not

identified by any of the forests and only one

compared diversity of past and present conditions.

Also missing were quantitative measures of the

distribution and abundance of plant and animal

species. Most forests (60 percent) used the percent of

total forest acreage in different age classes as a

surrogate measure of animal diversity. Seven forests

(35 percent) measured diversity as the percent

change in forestwide habitat capability for management indicator species. Specific measures of plant

diversity were not included, under the assumption

that animal (habitat) diversity reflects vegetative

diversity (167). (See also the following discussion of

indicator species.) The study concluded that although the 20 forests generally conformed with

NFMA requirements to provide for diversity and

show effects of outputs on diversity, the measures of

diversity were general values for tree age classes or

animal numbers, rather than specific measures for

plant and animal communities and species distribution and abundance. These measures were also

insensitive to effects of different management options on diversity (167).

Timber and range vegetation types are the most

common measures of diversity in these plans of

forests listed in table 6-1. The Bitterroot, Eldorado,

and San Juan Forests included old-growth forest, but

surprisingly, the Siskiyou did not--even though

old-growth forest protection has been an issue in that

region. Six of the forests (Coconino, Eldorado, San

Juan, Siskiyou, Nantahala/Pisgah, and Nicolet) included wildlife habitat measures in their inventories

of diversity. All of these measures of diversity,

however, fail to adequately evaluate spatial, temporal, and structural characteristics of biological diversity (137). Three of the forests have developed

special inventories to address these shortfalls. The

Eldorado National Forest greatly expanded its plant

inventories; the Siskiyou participated in a regional

inventory of vegetative communities that will include measures of fragmentation and biological

corridors; and the Nantahala/Pisgah, in response to

a successful administrative appeal based on the

inadequacy of the diversity section of the forest plan,

is evaluating alternative inventory methods to determine status and trend of diversity (137).

To compile information on diversity, the Chequamegon National Forest staff used data from the

Wisconsin Department of Natural Resources on

vertebrate species, selected sensitive and game

vertebrate species, rare vascular plants, and potential

research natural areas. The forest also used general

vegetation information from its Vegetation Management Information System (238). These data, like the

biological diversity data collected on other forests,

are incomplete in that no species list was available

for invertebrate animals and no information was

available for nonvascular plants, lichens, and fungi.

The Chequamegon Forest has taken steps to resolve

some of these problems by enlarging the scope of

diversity information and by focusing monitoring

efforts on species and processes of greatest public

concern or those most affected by forest management. Examples of programs to be added include

monitoring the reproduction of white cedar and the

use of various plant foods by mammals (238).

Several plans have been criticized for promoting

management practices that do not protect the biological resources of the National Forest System: forests

are being converted to monoculture, genetic diversity is not being enhanced, and animal habitats are

being fragmented (321). Plans from national forests

in Florida, for example, promote management practices that will convert longleaf pine forests into

stands of species that would not occur there naturally. The final plan for the Ouachita National

Forest, in Arkansas and Oklahoma, was criticized

for managing almost solely for pine forests and for

decreasing genetic diversity by artificially regenerating clearcut stands with pine. Restrictions on

clearcutting and pine plantations were considered

for 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 an

advisory coremittee were finally specified in the act.

The plans for the Arapaho/Roosevelt and Shoshone

National Forests (in Colorado and Wyoming, respectively) were criticized because they would

allow a high level of forest fragmentation. Biological diversity would not be protected (321).

Indicators

General Indicator Concept

An indicator has been defined as:

A characteristic of the environment that, when

measured, quantifies the magnitude of stress, habitat

characteristics, degree of exposure to the stressor, or

degree of ecological response to the exposure.8

Indicators have been used as an index of conditions

that are too difficult, inconvenient, or expensive to

measure directly (140). Indicators can streamline

investigations of environmental conditions by minimizing the number of characteristics that need to be

measured. Indicators may be of several kinds. Some

may be ecological in that they provide information

on the biological condition of a resource. Others may

be stressor indicators, providing information on

environmental hazards, or management indicators,

providing information on management activities.

While saving time and money, the indicator

concept has been criticized for presenting an oversimplified view of environmental conditions. Indicator species, in particular--in contrast to the

broader indicator concept that can include characteristics such as climatic fluctuations or levels of

nutrients in tree foliage in addition to individual

species—have been described as misleading:

Indicator species often have told us little about

overall environmental trends, and may even have deluded us into thinking that all is well with an environment simply because an indicator is thriving (184).

A poor selection process for indicator species could

lead to poor assumptions about the effects of an

environmental hazard, such as a chemical pollutant.

For example, assumin g that a chosen indicator

species will decline if the chemical pollutant is

harmful to its food source may not be effective if the

chosen indicator does not depend solely on that food

source. Declines in other species that do rely solely

on the affected food source might go unnoticed

because these species were not monitored.

Recommendations to make the use of indicators

more rigorous include: a clear statement of goals;

thorough biological knowledge of the indicator; and

peer review of assessment design, methods of data

collection, statistical analysis, interpretations, and

recommendations (140). The most useful indicators

will be sensitive to stress, responding to it rapidly in

a predictable way; be easy and economical to

measure; and be relevant to the goals of the

investigation (127). A set of carefully selected

indicators, rather than a single indicator species, is

more likely to exhibit all of the characteristics

recommended as selection criteria (184).

Forest Service Use of Management

Indicator Species

Forest Service regulations require the forests to

select and monitor a set of management indicator

species (MIS) (36 CFR 219.9). The Forest Service

regulations list five categories to be represented

when selecting MIS: 1) endangered or threatened

species identified at the State or Federal level; 2)

species sensitive to planned management activities;

3) game and commercial species; 4) nongame

species of special interest; and 5) ecological indicator species that are used to monitor the effects of

management practices on other species. Following

the general indicator concept, the MIS chosen to

represent these categories act as surrogates for

measuring environmental conditions of the forest

communities. Management indicator species differ

from other types of indicators in that: 1) they are

species (in contrast to characteristics); 2) they

indicate the effects of management activities (in

contrast to effects of other events such as natural

disasters or changes in rainfall); and 3) they indicate

the effects of management activities on forest

resources (not solely on other species). The use of

MIS assumes that some relationship exists between

a prescribed management activity and the presence

or abundance of the MIS (174, 189).

As with the indicator concept itself, several major

problems 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 and

Development Washington DC, September 1990.
122 . Forest Service Planning: Accommodating Uses, Producing Outputs, and Sustaining Ecosystems

not been set for the selection of species; training and

expertise to select, monitor, and analyze MIS have

been lacking; and some species are ignored in the

inventory process (174, 189). With no guidelines for

the selection of MIS, selection processes vary

among forests. Some are criticized for choosing an

insufficient number of indicators, others for choosing indicators that are not related to ecosystem conditions. The following examples illustrate specific

problems some forests have had with the use of MIS.

The Idaho Panhandle National Forests and the

Cibola National Forest fell short in their selection of

an adequate number of indicators and their collection of data on chosen indicators (42, 166). On the

Idaho Panhandle, no indicator species existed for

mature lodgepole pine which covers a major part of

these forests. Also on the Idaho Panhandle, no data

were available on populations or population trends

for most of the nongame indicator species (marten,

pileated woodpecker, and goshawks) (42). On the

Cibola, inventory data were also nonexistent for

population size and distribution of nongame indicator species (166).

The Chequamegon National Forest plan recognized 25 ecological community types, but only

identified 15 indicator species to evaluate conditions

in these communities. Deciduous trees dominate at

least half of this forest, but the stands were lumped

into two classes: young/mature hardwoods with

ruffed grouse as an indicator, and old-growth

hardwoods with the pileated woodpecker as an

indicator. Under this classification, several communities (a young, even-aged stand of red oak and red

maple, an uneven-aged pure stand of sugar maple,

and a mixed stand of basswood and yellow birch)

would all be lumped into one category. Tracking

populations of ruffed grouse and pileated woodpeckers would poorly represent changes in these communities or in their other constituent species (238).

Also in the Chequamegon plan, two species were

selected as aquatic indicators, but were dropped

from the list because ‘‘little management of aquatic

habitats is planned for this decade” (238). Thus the

potential effects of such management activities as

timber harvesting or road construction on aquatic

ecosystems are ignored. In addition, one of the

chosen indicator species did not depend on natural

conditions for reproduction in the forest. The muskellunge, a game fish stocked in the lakes and

streams in the Chequamegon National Forest by the

Wisconsin Department of Natural Resources, was

chosen as the sole “ecological” indicator for warm

water habitats in the forest. But because of artificial

stocking, muskie population numbers are inaccurate

indicators of the effects of national forest management (238).

A review of 104 draft and final plans for 118

national forests showed that the majority failed to

choose a wide spectrum of indicator species and

overlooked the advantages of selecting plants and

some invertebrates:

Ninety-three plans did not have any plants on their

MIS lists, other than species already listed as

threatened or endangered by the federal government.

Eighty-seven did not include any unlisted invertebrate animals, despite the fact that invertebrate

animals constitute the vast majority of living species.

Of the 1,439 MIS in these plans (excluding federal

threatened and endangered species), 50 percent were

birds, 27 percent were mammals, 17 percent were

fishes, two percent were reptiles and amphibians,

less than one percent were invertebrates, two percent

were plants, and two percent were multi-species

assemblages of birds, plants, fishes, or invertebrates

(321).

Thus, while birds and mammals can serve as good

ecological indicators for other species with smaller

area requirements, an MIS list composed only of

vertebrate animals will be inadequate for protecting

all rare plants or invertebrate animals in a given area

(321).

Indicator Species and a Monitoring Program

The selection of appropriate management indicator species must be combined with an adequate

monitoring program. The Forest Service regulations

state that:

Population trends of the management indicator

species will be monitored and relationships to habitat

changes determined (36 CFR 219.19(a)(6)).

The goal of monitoring MIS on the national forests

is to verify assumptions in the forest plans about

effects of management activities on ecosystem

health. Monitoring MIS can lead to needed changes

in management activities. Three important components of a successful monitoring program include:

1) a scientifically sound method for assessing populations of the MIS in question; 2) a reasonable

frequency of measurement; and 3) a standard for

population levels or degrees of change in population
—

Chapter 6--Biological Dimensions of Forest Planning ● 123

size, density, or distribution that triggers a reanalysis

of management activities.

Monitoring programs in many forest plans do not

meet these standards (32 1). Some plans propose

only to monitor habitats rather than populations,

while others call for only infrequent monitoring of

the MIS—populations may be counted only once

every 5 or sometimes 10 years. This infrequent

monitoring will only detect the most drastic population changes and will not alert the forest in time to

avert or alter destructive management activities.

Summary and Conclusions

Forest planning under NFMA requires a tremendous database accompanied by time, money, and

trained staff. Emphasis on timber management and

the lack of data on nontree outputs has hindered the

development of thorough and accurate biological

models to assist forest planning. Questions have

been raised on the validity of assumptions, the

adequacy of updating and maintaining data files, and

the use of appropriate scale. Future models to aid

planners in forest resource management must take

advantage of new technologies in data collection,

storage, and updating and must pay closer attention

to scale of analysis as well as to more comprehensive, integrated analysis of renewable resources.

NFMA and the forest planning regulations make

repeated reference to maintainingg biological diversity in the national forests. Treatment of this issue in

the plans, however, has not received favorable

reviews. The Forest Service lacks adequate inventory data to address diversity questions, and critics

assert that the agency has a short-term, myopic view

of conservation of biological diversity rather than a

long-term, comprehensive approach.

Problems with the use of management indicator

species make this requirement subject to varied

interpretations and criticisms. It is not economically

feasible to study all species on a forest; the MIS

concept offers a less costly alternative to tracking

environmental trends. Application of the MIS concept to the national forests, however, has been

described as neither efficient nor effective. Continued use of indicators on the forests should involve an

effort to improve the selection process as well as a

more comprehensive approach to evaluating the

forest ecosystem. This comprehensive approach

should include analysis of management indicators as

well as indicators of habitat conditions and ecological processes. The national forests may have numerous chances to revise and expand the characteristics

chosen as indicators, but interest in collecting

information for determiningg long-term trends discourages this from happening often. It is important

that the forests select an adequate number of

indicators that will provide the maximum amount of

information with reasonable monitoring ease.

297-904 0 - 92 - 5
Chapter 7

Technologies for

National Forest Planning
. .

.

.

Relevant

Types of

Contents

Page

Planning Decisions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . . . .

Planning Technologies . . .

Decision Support Technologies .

Impact Assessment Technologies

Supplemental

FORPLAN and

Technologies . . . . 

. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

Forest Planning . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

The Development and Selection of FORPLAN . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

What Is FORPLAN? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . .

FORPLAN’s

FORPLAN’s

Strengths . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

Weaknesses . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

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

Decisions and Tools . .

FORPLAN . . . . . . . . . .

Options for the Future

. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

. . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

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129

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134

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139
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 revising

forest plans. However, NFMA establishes various

resource quality standards, and specifies various

considerations for the planning process. While a

variety of techniques are available for organizing

and analyzing information to meet these requirements, the Forest Service chose one particular

computer model—FORPLAN--as the principal analytical tool for forest planning.

FORPLAN is a complex and expensive computer

program. Some have blamed FORPLAN for a costly

and time-consuming planning process, and have

asserted that FORPLAN has increased the controversy over national forest management. Congress

asked OTA to assess Forest Service planning partly

to determine if FORPLAN has helped or hindered

the process. This chapter briefly examines planning

technologies that exist, reviews the development of

FORPLAN, and discusses FORPLAN’s strengths

and weaknesses for supporting the forest planning

process.

RELEVANT PLANNIN G

DECISION S

To assess the planning technologies, it is necessary to understand the decisions to be made in the

planning process. As discussed earlier in this report,

the purpose of national forest management is to

accommodate uses and produce outputs while sustaining ecosystems. (See ch. 3.) Thus, technologies

that can allocate (analyze spatially) and/or schedule

(analyze temporally) could be useful in decisionmaking, while technologies that assess the effects of

decisions on ecosystems and values could be useful

in understanding the consequences of decisions.

Because of the concerns over clearcutting in the

early 1970s, NFMA focused on protecting the forest

environment during timber harvesting (123). (See

ch. 4.) NFMA included two particular provisions

that lend themselves well to computer analysis. The

first, section 6(k), prohibits most timber harvesting

from lands identified as not suited for timber

production, “considering physical, economic, and

other pertinent factors to the extent feasible, as

determined by the Secretary.” In essence, this

provision requires a land allocation decision, based

in part on an economic (temporal) analysis of timber

production.

The second provision, section 13(a), generally

limits timber sales (the allowable sale quantity, or

ASQ) to a level that can be sustained in perpetuity;

this requirement is commonly known as nondeclining even flow (NDEF). Assuring that the plans

provide this perpetual, sustainable flow is a longterm scheduling problem, based in part on the land

allocation decision under section 6(k).1 The long

timeframe for managing timber makes both the

allocation and scheduling decisions well suited for

analysis using computer technology.

These provisions of NFMA limit timber harvesting based on certain specified criteria. The MultipleUse Sustained-Yield Act (MUSYA) and NFMA

further require that timber harvesting be coordinated

with other uses. Decisions coordinated to allocate

and schedule the various uses and outputs are one

means to minimize conflicts and to accommodate

compatible activities. Again, computer models can

be useful in analyzing the allocation and scheduling

decisions for timber production as well as other uses

and outputs.

The various legal requirements of MUSYA and

NFMA imply a sequential analysis. Lands suitable

for timber production are identified, the ASQ is

determined, and finally timber management is coordinated with other uses and outputs. Notably, both

sections 6(k) and 13(a) provide exceptions to their

limitations on timber harvesting based on multipleuse considerations. Thus, arguably timberland suitability and ASQ are to be determined without

limitations based on multiple-use coordination (293).

However, Forest Service practices make these three

analyses (timberland suitability, ASQ determinalsome ~bs=erS ~ve~t~tit ~mnt~-a~M ~cli~ For~ts~i~ pl- procas Codd lad to d~b b the ASQ b ~ch

subsequent plan for a nationsl forest, contrary to the intent of nondefining even flow in NFh9A (163). Such an occurrence can apparently be made

insignificant with additional restrictions on the current models (134), and thus this Mlcuhy is not considered in this Assessment. However, further

analysis of this possibility by the agency maybe warranted.

–127–
128 . Forest Service Planning: Accommodating Uses, Producing Outputs, and Sustaining Ecosystems

tions, and multiple-use coordination) simultaneously. The regulations for implementing section 6(k)

specifically include multiple-use benefits for determining the suitability of lands for producing timber.

By including multiple-use benefits in determining

timberland suitability, multiple-use considerations

also have been included in determining the ASQ.

Thus, the Forest Service has chosen to combine

timberland suitability, ASQ determi nation, and multipleuse coordination in one large, allocation and scheduling problem.

TYPES OF PLANNING

TECHNOLOGIES

Two types of computer modeling are useful for

analyzing alternative plans. One approach—simulation—imitates the relevant system, and is used to

examine how important measures change when the

decisions or inputs change. The other--optimization--

attempts to maximize or minimize important measures within the system’s limits. Optimization models are often preferred for supporting decisionmaking, but may not be relevant if one cannot define all

the variables that should be optimized. Furthermore,

because optimization models (and the calculations

they require) are often much more complex than

simulations, they can be very expensive to use.

It is important to note that computer models are

not perfect duplicates of the real world. Reality is

generally too complex to replicate precisely. Thus,

models necessarily simplify the real world. Nonetheless, the results of useful models must approximate the actual results of management actions.

Models are tested (verified, in technical parlance) to

determine if their results are sufficiently similar to

reality to make the model useful. Computer model

results, however, are still only estimates of what will

happen. This, together with the human responsibility

for decisions, is why computer models are used to

support decisionmaking, rather than to make decisions.

Computer tools contribute to forest planning in

two ways—by assisting in allocation and scheduling

decisions and by assisting in estimating the consequences of decisions. Additional techniques can be

used to supplement and coordinate the technologies

that contribute to allocation and scheduling decisions and that estimate impacts.

Decision Support Technologies

Resource Scheduling Decisions

Resource scheduling decisions determine the

levels of uses and outputs that will occur over time.

Most scheduling tools used in business are optimization models, determining the ‘best’ (typically most

profitable) timing for activities within the constraints of the systems. Common scheduling models

include inventory models for reordering decisions,

transportation models for the delivery of goods, and

models for determining the optimum mix of outputs

from a common input. These latter two models both

use linear programming, a tool that achieves an

objective function within the constraints of the

system. For example, linear programming is used in

determining the output mix in the refining of crude

oil: the output of the model (the solution) identifies

the most profitable mix of gasoline, kerosene, fuel

oil, and other petroleum products, within the constraints of current prices for each product; the

relationship among the products (producing more of

one product reduces the amount of other products

that can be produced); the costs to produce each

product (which increase as the quantity produced

from a barrel of crude oil increases); and the capacity

of the refinery.

Natural resource scheduling is, in many ways,

comparable to the oil refinery decisions. Forest lands

have the ability to produce a variety of uses and

outputs, with varying prices and values. The uses

and outputs are related, sometimes complimentarily

but also in ways that are competing or incompatible.

The financial and environmental unit costs vary, in

part, with the level of each use and output produced.

And production is limited to levels that can be

sustained in perpetuity. As described below, the

Forest Service chose a linear programming approach

—FORPLAN--for assisting in resource scheduling

and other forest planning decisions. The requirement

to assure sustainable timber production over long

periods and the complex interrelationships among

the various resources make linear programming

quite useful in attempting to maximize resource uses

and outputs within long-run, ecological limits.

Linear programming, however, has inherent limitations in supporting resource scheduling decisions.

First, linear programming requires massive amounts

of data to define the interrelationships among

resources and the changes that result from manage-
Chapter 7—Technologies for National Forest Planning . 129

ment activities. Linear programming also is deterministic—risk and uncertainty cannot be included in

the model, even though they are common in natural

systems (65, 234). Finally, linear programming is

linear—all relationships must be direct, continuous,

and symmetrical (reversible).2 Linearity is a problem because: 1) inputs on one site can affect the

outputs and management costs of other sites—there

are indirect effects of management (14, 146); 2)

some inputs, such as facilities, cannot be adjusted in

small increments--they are not continuous functions (14, 179); and 3) ecosystems may have

thresholds-irreversible changes can result from

management activities (65, 118).

Land and Resource Allocation Decisions

Land and resource allocation decisions determine

how uses and outputs are combined (or separated)

over space. Thus, technologies for supporting allocation decisions must be able to evaluate spatial

relationships among resources. Linear programming

has some capacity to account for spatial relationships (122), and including spatial details substantially increases the size, cost, and complexity of the

model (1 18).

The Forest Service has traditionally examined and

presented spatial relationships with maps, which are

a part of every forest plan. However, the maps have

generally been produced by hand, with an enormous

investment of time and energy. Overlays can be used

to combine different types of spatial information, but

the process of creating and using overlays is

cumbersome and expensive. Thus, despite its importance, spatial analysis for land and resource allocation decisions in forest planning has been limited by

the shortcomings of FORPLAN and current mapping practices.

Geographic information systems (GIS) are basically computerized mapping systems that can store,

manage, and analyze spatial information. GIS are

not optimization systems, but are very useful for

examining spatial questions. After the user defines

the relevant spatial information to be combined, GIS

can display locations of specified conditions (e.g.,

mature timber on moderate slopes) or of situations

sensitive to certain management activities (e.g.,

highly erodible soils or critical habitat for an

endangered species). The Forest Service has been

testing a variety of GIS, and expects to have GIS

available at each national forest eventually.

GIS also has limitations for use in forest planning.

First, the systems require sizable investments in

computers, plotters, and software. The General

Accounting Office (255) recently concluded that the

Forest Service has not adequately analyzed the

alternatives to the estimated $ 1.2-billion investment,

and to date, Congress has not funded GIS acquisition

by the Forest Service. In addition, GIS require

spatial information, and putting such information

into the systems is generally an expensive and

time-consuming manual process. However, the cost

of putting spatial information into a GIS may not

much exceed that of manual mapping currently used

in forest planning.

Impact Assessment Technologies

Ecological and Environmental Impacts

Examining the likely ecological and environmental impacts of management decisions is an

important part of forest planning. Resource simulation models are the principal technologies used for

this purpose. Resource simulations quantify the

relationships within natural systems, and attempt to

estimate the likely results of management actions.

Many simulations have been developed for single

resources; the most common are timber growth-andyield models, although the Forest Service has also

developed sediment yield and wildlife habitat models. A few have attempted to simulate changes in

forest and ecosystem structure over time (with and

without various management activities), but these

more comprehensive models are usually more expensive 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 in

developing resource simulation models (146). However, in contrast to scheduling and allocation models, which address common decisions, the diversity

of resources and resource relationships typically

leads to unique simulation models that address

locally or regionally specific issues and problems.

The diversity of national forest lands and resources

has prevented the development of universal models.

The existing models are often used in modifying the

general FORPLAN model to address local issues,

%inear programm ing does not actually require freed linear relationships. Cumilinear and other relationships can be approximated with multiple

equatiom, if the relationships are direct+ continuous, and symmetrical.
130 ● Forest Service Planning: Accommodating Uses, Producing Outputs, and Sustaining Ecosystems

but this has not always been done well (234), and

some important data and relationships are poorly

known (72, 278).

Economic Impacts

Predicting the economic consequences of management decisions is another important part of forest

planning. The economics of management is typically examined by comparing the benefits and costs

of the proposed activities. Distinct models for such

analyses exist, but in forest planning it is done with

FORPLAN. FORPLAN’s objective function (the

goal) is to maximize present net value (PNV)---the

value of uses and outputs minus the costs, with

future values and costs discounted to the present.

(See ch. 8 for a fuller discussion of strengths and

weaknesses of economic analysis in forest planning.)

The traditional tool used for assessing local

economic impacts is input-output analysis. An

input-output model describes an economy in terms

of its quantitative financial interactions among

manufacturing, service, and other sectors. The Forest Service has developed a standardized inputoutput model with localized adaptations—IMPLAN—

for estimating economic consequences on each

national forest. IMPLAN is useful for appraising the

total economic impacts of a forest plan, but is

insufficient for evaluating impacts on communities

(278). (See ch. 8 for a more thorough analysis of

IMPLAN and its limitations.)

Supplemental Technologies

Database Management Systems

Computerized databases are often used to store

and manipulate inventory information for the national forests. Computerized databases are essentially sophisticated filing systems, with the ability to

store, sort, and rearrange massive amounts of data.

Information sorting is the only analytical capability

of databases, and thus databases are not really

analytical tools. However, relational databases can

store inventory information with site relationships,

and therefore, can provide data for other allocation

and scheduling models and for impact assessment

tools.

In addition, one computerized database can be

linked to other databases. If uniform structures and

definitions are used for inventories, individual

databases can be aggregated, creating a “corporate

database’—i.e., nationwide access to local data on

national forest lands and resources. This would

certainly assist the agency in the RPA planning

process. However, the Washington Office has not

yet decided on the nature and structure of such a

corporate database. Many forests are delaying the

initiation of forest plan revisions until they receive

some direction on database structures and definitions (146, 166).

Knowledge-Based Systems

Knowledge-based systems (KBS), also known as

expert or rule-based systems, are relatively new in

natural resources management. Expert systems can

be optimization models, depending on the rules

incorporated into the system, but the goal for such

systems is to replace traditional computer logic with

a more humanlike reasoning process (146). Currently, KBS are usually based on ‘‘if-then’ rules,

such as “if tree age exceeds the specified rotation

age, 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 can

be scheduled for fish habitat improvement.” However, because of our limited understanding of the

rules and limits of natural systems, KBS are used

primarily for relatively simple, repetitive decisions.

KBS can also be interactive, such that systems ask

the users a series of questions with subsequent

questions depending on previous answers. In this

capacity, KBS can assist decision support and

impact assessment technologies by assuring that

appropriate models and information are used. The

Forest Service is developing a KBS to assist in

assuring that project planning complies with NFMA

and NEPA. However, KBS could be expanded to a

broader role in coordinating information and analysis in forest planning.

Integrated Systems

Integrated systems combine various technologies

with systematic, automated linkages. Computerized

databases can be linked with GIS for allocation

decisions; with resource simulations for estimating

ecological and environmental impacts; and/or with

a linear programming model for scheduling decisions. Simulations and GIS can also be linked with

linear programmingg. The Forest Service is developing an integrated system—INFORMS---coordinated

through the Rocky Mountain Forest and Range

Experiment Station in Fort Collins, Colorado. Parts
Chapter 7—Technologies for National Forest Planning . 131

of the system have been used in various locations,

but the integrated system has not yet been implemented (146). Another integrated system—TEAMS

—has been developed at Northern Arizona University in Flagstaff, Arizona (54). TEAMS is used in

teaching, and has been applied successfully on the

Coconino National Forest and on other lands (146).

As with all planning technologies, integrated

systems have their limitations. First and foremost,

the shortcomings of the component technologies

must be recognized. Computer models cannot give

perfect answers, because the models necessarily

simplify reality, and results are less precise than they

appear (13, 14). Not only modelers and analysts, but

more importantly, managers and the public, must be

aware of the limits of the technologies (60). Furthermore, the technologies and linkages must be understandable so that the public (and agency employees

not involved in planning) can recognize what is

being evaluated, what the decision criteria and other

critical standards are, and how the results will be

used. However, given these cautions, integrated

systems and the technologies that they integrate can

be very useful in land and resource management

planning for the national forests.

FORPLAN AND FOREST

PLANNING

Historically, forestry has focused on sustaining

the production of timber and other forest products

over long periods of time. The European tradition

was to manage forests to achieve a ‘‘fully-regulated

condition, ’ with stable annual timber harvests and

approximately equal forest areas in various stages

from seedlings to “mature’ stands. Forestry education in America followed this tradition (63), but

European forest regulation could not be adopted

easily for the unmanaged U.S. forests (122). Various

methods were developed to regulate harvest rates for

old-growth timber, and to convert such stands to

more productive conditions. These methods were

essentially designed to determine the allowable

cut—the volume of timber that could be harvested

annually while forest productivity was maintained.

Relatively simple approaches to determining

allowable cuts were used until at least the 1950s

(122). However, two changes complicated the determination of allowable cuts. The first was the

increasing importance of the national forests for

timber and recreation, which led to the enactment of

the Multiple-Use Sustained-Yield Act of 1960, as

described in ch. 3. The second was the recognition

in the early 1960s that timber harvests from private

lands, at least in Washington and Oregon, could not

be sustained at their historic levels. These concerns

and the development of computer models led to

more sophisticated approaches for determining the

allowable cut from the national forests.

The Development and Selection of FORPLAN

Prior to 1973, the Forest Service had as many as

48 different types of functional plans for the national

forests (212). In the initial response to NEPA, the

Forest Service chose to develop integrated unit plans

for areas within the national forests. RPA echoed

this direction by requiring “land and resource

management plans for units of the National Forest

System,” prepared under an interdisciplinary approach. NFMA then provided substantial direction

on what to consider in developing plans.

Two linear programming approaches were developed initially to assist in integrated, multiple-use

management planning for the national forests. One

approach, the Resource Capability System (RCS),

focused on site-specific responses to management

alternatives. RCS analysis was generally organized

by watersheds, and the model provided timestreams

for resource yields, site-specific area control, and a

balanced treatment of all resources (i.e., all resource

outputs were included in the objective function)

(125). However, RCS was not widely accepted because of its emphasis on watershed concerns (122)

and because of its inadequacies for timber harvest

scheduling and control (125).

The other approach was the development of a

long-term timber harvest scheduling model, intended to assure the biological sustainability and

multiple-use compatibility of harvest levels over an

entire national forest (122). The frost such model was

the Timber Resource Allocation Model (Timber

RAM), developed in 1971. However, concerns about

a timber bias and increasing interest in site-specific

environmental effects led to the development of a

more sophisticated timber harvest scheduling model,

the Multiple Use-Sustained Yield Calculator

(MUSYC). However, MUSYC was considered to

be just a more sophisticated timber harvest scheduling model, rather than an integrated resource management model (122). Finally, FORPLAN was developed in the late 1970s to overcome some of these
●

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

limitations. FORPLAN followed the basic approach

established in Timber RAM and MUSYC, but was

modified to incorporate some of the advantages of

RCS, such as timestreams for yields, improved area

control, and an objective function that included all

resource outputs (122).

In 1979, as planning was beginning under the new

NFMA regulations, the Forest Service became

concerned that confusion in management direction

and excessive cost might result from having various,

competing computer models to assist forest planning. On December 3, 1979, Associate Chief

Douglas Leisz sent a letter to regional foresters and

staff directors designating FORPLAN as the primary

analysis tool to be used in forest planning (125).

FORPLAN was chosen because it addressed two key

issues in forest planning: cost efficiency, and an

allowable timber sale quantity (the NFMA term for

allowable cut) within constraints (123). With

FORPLAN, the Forest Service felt it would have a

consistent, unified approach to forest planning

(122).

FORPLAN has evolved substantially over the

past 12 years (125). As a result, there are two distinct

versions of FORPLAN, and more than 10 releases

(upgrades) of each version (64). Thus, more than 20

different FORPLAN models have been used in

forest planning. Furthermore, each national forest

structures the FORPLAN inputs to analyze relevant

problems for that forest (173). In essence, each

national forest has used a unique FORPLAN model

in developing its forest plan, and will probably use

a different FORPLAN model when it revises its

forest plan.

What Is FORPLAN?

As noted earlier, FORPLAN is basically a linear

programming model. It has three distinct parts. The

first organizes the required information into the

structure necessary for linear programming; technically, this is called the “matrix generator, ’ because

linear programming uses matrix algebra. The second

part is the calculator-the linear program itself. The

Forest Service uses commercial linear programming

software for this. The third part of FORPLAN

presents the solution in a variety of formats, to assist

in understanding and using the results; this part is

called the “report writer, ’ because it produces

various displays of the results.

Linear progr amming is a technique for finding the

best possible combination of outputs within specified limits. Thus, linear programming essentially has

three components: 1) the objective function (the goal

to be maximized or minimized), 2) the constraints

(the specified limits), and 3) the production functions (the relationships between the constraints and

the objective function).

The Forest Service has directed that economic

criteria will be used for the objective function in

FORPLAN. This function is intended to include all

national forest uses and outputs, using market prices

or some other relevant value for unpriced outputs.

(See ch. 8 for more information on valuation

techniques.) Future values and costs are discounted

to the present for comparing alternative investments.

(Again, see ch. 8.) The objective is then to maximize

the present net value of outputs by emphasizing

production of the most “profitable” outputs (those

with the largest difference between the price/value

and the cost of production). For example, if recreation is valued at $10 per unit and timber is priced at

$8 per unit, and if the costs to produce additional

units is $6 for each, FORPLAN will emphasize

recreation, within the specified constraints.

FORPLAN will not necessarily choose only recreation, or even more recreation than timber; the

selection depends on how recreation and timber

outputs are related to the constraints.

A large number and wide variety of constraints are

used in FORPLAN (122). Some constraints are

absolutes—total forest area, productive capacity,

minimum requirements or production targets, budgets, etc. FORPLAN also includes “flow constraints,’ principally to assure sustained production

of timber and other outputs over long periods; as

described above, one flow constraint--nondeclining

even flow of timber-is specified in NFMA. A third

category is relational constraints, which allow the

user to specify relationships among management

activities and outputs; for example, road construction into a specific area could be required before

timber harvesting is allowed there.

Production relationships connect the constraints

to the objectives. In FORPLAN, these relationships

are generally defined by analysis areas and management prescriptions (specific patterns of related

activities). Each prescription in each area includes

costs and output yields, to relate possible activities

to the objective function, and is aggregated for each
—

Chapter 7—Technologies for National Forest Planning ● 133

of the relevant constraints. The prescriptions applied

to analysis areas are called “decision variables,”

and FORPLAN selects among possible combinations to maximize the objective function while

meeting all of the constraints.

FORPLAN’s Strengths

FORPLAN has been used because it performs

certain tasks very well and because it helps organize

planning around certain issues. The strengths of

FORPLAN have been described as: its analytical

capacity, its focus on important issues, its common

language for analysts, and its protection of agency

discretion.

Analytical Capacity

One reason the Forest Service accepted linear

programming and FORPLAN is that it can be used

to consider thousands of possibilities (combinations

of prescriptions and analysis areas). Linear programming is used because the number of decision

variables to consider is beyond the capacity of the

human mind (122). For example, in determining

whether to manage an area for timber production,

one must consider the productivity of the land for

timber, the economics of timber management, the

continued flow of timber over 100 years or more, and

the relationships between timber management and

water flows (quality and quantity), recreation use,

big game habitat, endangered species protection,

and other outputs and ecosystem requirements. In

addition, such an analysis must be conducted for

each area that might include timber production as

part of the area’s management. FORPLAN is a tool

that, with the appropriate constraints, can perform

such a complicated analytical task.

Focus on Important Issues

Most of the important values of the national

forests are related to trees and the manipulation of

tree vegetation—wilderness, ancient forests, timber

production, recreation development, visual quality,

water flows, and the like (64). Concerns particularly

focus on timber management—how much timber to

harvest and from which lands.

To foresters ..., the important issues in forest

planning relate to active manipulation of the forest,

and such planning should focus on what timber

harvest levels can be sustained over time, given the

objectives and constraints from all forest uses (123).

FORPLAN focuses on these issues. FORPLAN is

structured to examine land allocations to various

management prescriptions, many of which include

timber production. FORPLAN relates timber management activities to the other uses and values of the

national forests. And, FORPLAN results are organized to provide information on land allocations

especially with regard to timber production, and on

timber and other output levels. Thus, FORPLAN is

useful in addressing important national forest management issues.

FORPLAN, or a similar model, is also probably a

necessary tool for forest planning. As noted earlier,

NFMA limits the allowable timber sale quantity to

a level that can be sustained in perpetuity-i. e.,

nondeclining even flow. A computerized model is

undoubtedly necessary to analyze long-term timber

harvest schedules, and thus to determine if the

nondeclining even flow constraint is met. For

several decades now, the simple formulas for

determining the allowable cut, generally based on

current growth and on harvesting the remaining

old-growth timber, have been inadequate, and will

probably remain inadequate for assuring sustainable

timber production from Federal lands.

Common Language for Analysts

One of the problems in interdisciplinary efforts is

that the various disciplines and specialties use

different terms and measures for their particular

concerns and problems. The direction to use

FORPLAN required foresters, hydrologists, biologists, archaeologists, landscape architects, and others to deal with one model to address all the issues

and concerns (64, 278). Thus, each of these specialists had to learn how to translate their particular

concerns and problems into a common format. The

requirement forced the specialists to work together,

and to communicate among themselves. The use of

a common model compelled interdisciplinary teams

to be truly interdisciplinary-to combine their

specialties for assessing management alternatives.

Some have suggested that FORPLAN, and quantitative analysis generally, has protected against

“professional omnipotence. ” In this view, computer models and analyses:

. , . prevent professional groups within the Forest

Service, especially foresters, from imposing their

objectives for management of the forest on the rest

of society (123).
134 . Forest Service Planning: Accommodating Uses, Producing Outputs, and Sustaining Ecosystems

Others note that the Forest Service may have simply

replaced professional wisdom with computer analysis for explaining the decisions (64), and that

decisions based on computer analysis may be no

more acceptable to the public than those based on

professional expertise were in the late 1960s and

early 1970s. Nonetheless, FORPLAN has shifted

power within the agency from the traditional resource staffs toward the analysts and planners of the

interdisciplinary teams (64).

Protection of Agency Discretion

Some observers have asserted that FORPLAN has

become a shield to thwart the efforts of interest

groups to shift national forest management in

various directions. The complexity of the issues

analyzed and the multitude of constraints limit the

ability of analysts outside the Forest Service to

understand the process well enough to know where

and how to modify the analysis to get the desired

results. According to the model’s principal author,

K. Norman Johnson, FORPLAN:

. . . is a formidable roadblock to gaining leverage to

push the national forests in any direction other than

the one they wish to go. The complexity and

subtleties of its options, the comprehensiveness of its

view, the incredibly ambitious task given to it by the

national forests, and the tremendous variance in its

use from forest to forest makes it difficult to

understand . . .

Thus FORPLAN is very effective at preserving

local agency discretion. It represents a formidable

way for the national forests to insulate themselves

from their critics (123).

The difficulties in understanding FORPLAN is a

weakness of the model, as will be discussed below.

Furthermore, some have hypothesized that

FORPLAN has shifted criticism and control from

local interests to national interests, giving greater

power to such centralized critics as the Office of

Management and Budget, the National Forest Products Association, and The Wilderness Society (23).

Thus, FORPLAN may not provide as much protection for local discretion as some have suggested.

FORPLAN’s Weaknesses

As many observers have noted, FORPLAN has

numerous weaknesses. Some are inherent in linear

programming; as discussed earlier, linear programming cannot include risk and uncertainty, and

assumes continuous, direct, and reversible relationships among variables. The FORPLAN model has

numerous unique shortcomings, such as massive

data requirements, use of economic criteria for the

objective function and the importance of constraints,

lack of spatial details, and the ‘black box’ nature of

the model. Additional problems exist with the

system for supporting and using FORPLAN, such as

documentation problems, inadequate verification,

the loss of expertise, and the poor understanding of

how results can be used in decisionmaking.

The FORPLAN Model

Data Requirements—Linear programming requires massive amounts of data, and in terms of size

and complexity, FORPLAN has extended the frontiers of linear programming (14). As noted above,

FORPLAN requires analysts to develop costs and

output yields in order to relate activities to the

objective function, and relevant measures to relate

activities to absolute, flow, and relational constraints. For each management prescription (such as

clearcutting with site preparation for natural regeneration) and each analysis area (areas with similar

resource conditions and responses to the prescriptions), the user must identify the expected schedule,

over 100 years or more, for at least: 1) the

implementation costs; 2) the quantitative yields for

all relevant outputs (timber harvests, water flows,

animal populations, recreation uses, etc.); and 3) the

relationship to the various constraints (endangered

species habitat protection, soil erosion limits, nondeclining even flow of timber, maintaining biological

diversity etc.). Thus, FORPLAN clearly requires

enormous amounts of information, which undoubtedly exceed the limits of knowledge.

Many critics have noted that data are inadequate

to meet FORPLAN’s needs. Timber inventories are

often out-of-date (64). Yield information for other

resources is rare, and ‘‘Assessments [of nontimber

resources] are subject to large measurement errors’

(72). In its recent internal critique, the Forest Service

noted the lack of data on water, old-growth timber,

range condition, and threatened and endangered

species, and the lack of tools for addressing cultural

resources, biological diversity, erosion and sedimentation, cumulative impacts on water quality,

visual quality, and wildlife habitat capability (278).

The lack of data could lead the various resource

specialists to coordinate their needs, but ‘the agency

still has not developed an effective strategy to

develop and manage data systems” (64).
Chapter 7—Technologies for National Forest Planning . 135

One particular data problem could cause serious

legal difficulties for the Forest Service. NFMA

requires assurance that clearcutting is used only

where it is the optimal cutting system. However,

“FORPLAN has an inherent bias for even-age

timber management’ systems, such as clearcutting

(64), and comparable yield data for uneven-age

timber management do not exist (278). “Research

and practice has largely ignored . . . uneven-aged

management systems’ (64). This problem has not

been widely recognized.

The lack of necessary data typically leads analysts

and specialists to extrapolate existing data and to

make various judgments and assumptions, as needed

(64). “In most cases, modeling coefficients [the

internal data] were based on anecdotal or ‘bestguess’ information rather than scientific quantification” (13). This is not all bad, especially when it

leads to cooperative, interdisciplinary discussion

and learning (64). However, in at least some cases,

the resource specialists have become resource advocates, and subordinated the common good of the

planning team to the needs of their disciplines (13).

At this point, it is unclear whether FORPLAN has

contributed to integrated resource management, as

some have suggested (278), or has simply created

“the illusion of interdisciplinary integration of all

multiple uses’ (13).

Objectives and Constraints-As noted earlier,

the goal of the FORPLAN model is to maximize the

present net value of national forest uses and outputs.

While some have argued that this was clearly the

intent of Congress (246), others are not convinced:

It is more difficult to find justification for this

economic approach in NFMA than the focus on

timber management. . . A much stronger focus is the

assurance of protection of the forest environment

during all actions (123).

The economic objective function has added to the

difficulties with data in building and using

FORPLAN, because all resource uses and outputs

must be measured in dollars, even though only

timber has a true market price (64). (See ch. 8 for a

discussion of valuation techniques for unpriced

resources.)

All goals for national forest management are

included in FORPLAN through constraints on the

model. Insufficient constraints can lead to unrealistic estimates of uses and outputs (and thus to

infeasible targets), but excessive constraints can

cause capabilities to be underestimated and lead to

significant opportunity costs (50).

The most limiting constraints in FORPLAN have

been the flow constraints, especially nondeclining

even flow for timber (278). Timber harvests are

regulated by total timber growth, which is determined by the area allocated to timber management

and by investments in timber growing. However, in

forests with substantial timber inventories (i.e., with

old-growth timber), nondeclining even flow limits

timber harvests largely by the amount of land

allocated to timber harvesting. In many western

national forests with substantial old-growth timber,

timber harvest flow constraints have often been

‘‘used as surrogates for restrictions on harvest for

economic, social, political, or environmental reasons” (122). Easing the rigid nondeclining even

flow constraints could substantially increase all of

the uses and outputs, without compromising longterm timber productivity (278). However, to the

extent that timber flow constraints have been used as

surrogates for other values, easing this requirement

for FORPLAN analyses may be politically infeasible.

The choice of tools and data is not objective,

because the selection carries implicit values and

emphases (50, 51). FORPLAN maximizes the value

of uses and outputs. Nonuse values, such as visual

quality and soil productivity (or having undisturbed

ecosystems or providing a natural resource legacy),

can only be included as constraints to maximizing

uses and outputs. The value implicitly associated

with a constraint can be determined, but this is a

costly and time-consuming process that has not been

done extensively in forest planning (64). As constraints, nonuse values must be fully achieved at the

specified levels, but FORPLAN grants no additional

benefits for exceeding the specified levels. Thus,

FORPLAN can examine tradeoffs among uses and

outputs, but cannot readily examine tradeoffs between outputs and protection. This approach has

been described as reactive--preserving current conditions and mitigating damages-rather than as

proactive—managing ecosystem functions (234).

Therefore, FORPLAN may not provide the balance

among accommodating uses, producing outputs, and

sustaining ecosystems as is intended in the laws

guiding national forest management.
136 . Forest Service Planning: Accommodating Uses, Producing Outputs, and Sustaining Ecosystems

Spatial Limitations--FORPLAN’s capability to

accommodate spatial relationships is limited. Initially, analysis areas were simply areas with similar

conditions and responses to management activities--

areas with comparable soils, similar timber stands,

identical costs, etc. The areas did not need to be

contiguous; in fact, version 1 of FORPLAN did not

allow the analyst to specify whether the areas were

contiguous (122). In version 2, spatial relations

among analysis areas could be specified (65).

However, including spatial details substantially

increases the size of the model (and hence the cost

to use it), and only a few spatial configurations can

be analyzedinFORPLAN(118).

Spatial relationships are very important in land

and resource management:

In terms of outputs such as water, wildlife and

fish, and aesthetics, it is probably more important

how a management action (for example, a timber

harvest) is spatially laid out than how many acres are

involved (1 18).

Furthermore, limited spatial details lead FORPLAN

(and all other optimization models) to overestimate

the feasible outputs (54, 72). This happens because

implementation requires local adjustments and sitespecific tradeoffs that cannot be included in

FORPLAN (146). Unless additional spatial analysis

is conducted, the use of FORPLAN to establish

output targets in the forest plan can lead to planned

targets that exceed the feasible productive capacity

of the forest.

The “Black Box” Nature—FORPLAN is a very

large and complex computer model; its complexity

increases with the number of land areas, outputs,

practices, and years being analyzed (51). In some

respects, FORPLAN has gotten so complex that

even professional users fail to understand model

results.

It is possible to build a model that is so complicated that even the analyst no longer understands

why certain outputs are identified as optimal . . .

The level of sophistication, and the concurrent

ability to hide assumptions and manipulate data,

have risen to the point that even trained users are not

always aware of the ties that bind (122).

Furthermore, the data and constraints in FORPLAN

can be, and at times probably have been manipulated

to produce specific preferred results (13).

Some interest groups believe that the data, the

models, or the analysis is, or has been, intentionally

or unintentionally distorted, twisted, or slanted to

rationalize certain conclusions. Even worse, if these

suspicions are occasionally true and discovered, then

the entire analytical system, the analysts, and the

planning process risks rejection. I think some of this

has happened (64).

The sheer size and complexity of FORPLAN, or

of any other computer model, lead to a distrust of the

model (64, 234).

The ‘black box’ nature of FORPLAN allows for

data errors and hidden assumptions to go undetected

(14).

The frequent modifications to FORPLAN and the

resulting variety of FORPLAN models have added

to the confusion (173, 179). Finally, FORPLAN has

not been widely available for public examination

and testing (123); however, the recent development

of a FORPLAN model that can be used on a personal

computer will alter this condition (64). All in all,

FORPLAN has probably contributed to Forest

Service difficulties in communicating with the

public.

The FORPLAN Planning System

Documentation-The lack of model documentation has posed problems for FORPLAN. Documentation is needed to inform the public about

FORPLAN, and to assure that its use is consistent,

not arbitrary and capricious (51). However, “formal

documentation [of the FORPLAN model] has always lagged well behind [the system’s] development’ (125). Although FORPLAN has been used

since 1980, the final user’s guide was not available

until May 1986 (125), and scientific publications

describing the system were sparse for the first

several years (123). Thus, it has been difficult for

agency analysts and outsiders to examine and review

the technical structure of the model.

A related problem is the lack of documentation of

how FORPLAN has been used and on the underlying

assumptions, yield data, etc. The forests have

maintained “unclear and incomplete records such

that new analysts could neither duplicate nor understand what had been done previously” (278). This

lack of documentation could lead to successful legal

challenges on the grounds that the analysis was

arbitrary and capricious.
—

Chapter 7—Technologies for National Forest Planning . 137

Verification--Verification of the various assumptions, yield tables, and other inputs to

FORPLAN has generally been inadequate (179).

Unverified systems have undoubtedly been used

because of the need for immediate answers in the

ongoing forest planning process (146). Inadequate

initial verification is not a fatal flaw, if forest plan

implementation is monitored in a manner which

allows the assumptions, yields, and other

FORPLAN inputs to be examined; plan monitoring

was intended, in part, to verify FORPLAN and its

data (146). However, to date, monitoring has been

inadequate for this task. (See ch. 6.)

Agency Expertise-In response to the direction to

use FORPLAN, the Forest Service developed a pool

of talented analysts and modelers (64, 146), and

seems to have provided adequate training for using

the system (278). However, retaining this expertise

has proven to be more difficult. Mixing these experts

with the traditional specialists within the Forest

Service has led to “culture shock” and has created

some hostility toward the analysts (64, 146). Furthermore, delays, poor data, and other planning

difficulties led to disillusionment and “burnout”

among analysts (64, 146). Apparently fruitless

efforts also have contributed to low morale (50).

Finally, the analysts often felt locked into their jobs;

there has been no career ladder for talented individuals to move up in the organization (278). That the

Forest Service still has the personnel to use and

develop FORPLAN and other models is a tribute to

the agency’s tenacity and commitment, but additional steps may be necessary to assure that these

people are retained.

Relationship to Decisionmaking—A major problem has been comprehending how FORPLAN analyses can be used in decisionmaking. The lack of

‘‘clear understanding of the relationship between

analysis and decision making” has led to many

invalid and useless analyses (14). Analysts are

typically separated (physically and by education and

experience) from the decisionmakers (123), and

managers often have not understood the limits of

FORPLAN (64)--’ ’people took FORPLAN and its

results as gospel’ (278). Unless they are familiar

with computers, people commonly do not recognize

that models “are dumb [and] do exactly what they

are told’ (64).

FORPLAN can be useful in assisting Forest

Service decisionmaking, if its limitations are understood.

FORPLAN’s usefulness [is] as an aid to understanding the nature of forest planning problems [not

as optimal answers]. . . Its major purpose is to

provide insight into the behavior of multiple resources and their interactions, which in turn can be

used to guide the development of effective plans and

decisions, The model is more appropriately used to

prevent wrong decisions than for making “right”

decisions (13).

Virtually all analysts recognize that models are most

useful for examining possibilities, and that using

FORPLAN to obtain answers can waste money and

inhibit development of a publicly acceptable forest

plan. “The phrases ‘FORPLAN says’ and ‘our

model says’ need to be purged permanently’ from

conversations with the public (64). Analysis is

intended to help managers ‘‘understand the forest,

its potentials, limitations, and constituencies, and to

use this knowledge to find a balanced, acceptable

course of action” (64). Thus, FORPLAN is simply

a tool, to be used with other tools in preparing

implementable forest plans.

SUMMARY AND CONCLUSIONS

NFMA does not prescribe the use of any particular

technology in forest planning, but various computer

technologies can be very useful for analyzing

alternatives and assuring requirements are met. The

Forest Service designated FORPLAN as the primary

analytical tool for forest planning, but the many

shortcomings of the model and controversies over

forest planning have led some to question whether

FORPLAN may be part of the problem, rather than

part of the solution.

Decisions and Tools

As discussed earlier, the purpose of national forest

management is to accommodate uses, produce

outputs, and sustain ecosystems. (See ch. 3.) In

forest planning, important decisions about the scheduling (over time) and allocation (over space) of uses

and outputs can be examined using various computer models. Linear programming is often used for

scheduling decisions in business, and such an

approach is useful in forest planning for examin ing

the sustainability of uses and outputs over long

periods. Linear programming also has some capacity

for analyzing allocation decisions, but other tech-
138 ● Forest Service Planning: Accommodating Uses, Producing Outputs, and Sustaining Ecosystems

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 impacts

of forest management is also important for planning.

Resource simulation models are useful for examining environmental and ecological implications, and

can be used to provide input for scheduling and

allocation models, but more development is needed

to provide sufficient analysis for forest planning.

(See ch. 6.) Economic impacts can be evaluated by

examining the benefits and costs of activities over

time and by estimating the effect of management

alternatives on local employment and income; the

benefit/cost analysis is included within the structure

of FORPLAN, and the Forest Service generally uses

an input-output model--IMPLAN--to estimate local

economic effects. (See ch. 8.)

Additional technologies can be used to supplement the decision support models (for scheduling

and allocation analyses) and the impact assessment

models (for ecological and economic analyses).

Database management systems can be used to

maintain and coordinate inventory and other data

used by the various analytical models. A “corporate’ database (i.e., national access to consistently

measured, collected, and stored data) would be

useful, but the Forest Service has not yet set

standards for such a database. Knowledge-based

systems (also known as expert systems) are useful

for rule-based decisions, but the state-of-theknowledge on forest and rangeland systems is too

primitive to develop more than simple decision

rules. However, knowledge-based systems can also

be interactive (i.e., questions for users, with the

answer determining the subsequent question), which

opens numerous possibilities for forest planning.

Finally, integrated systems provide for automated

linkages among other technologies, and thus can be

very useful for coordinating analyses; however,

integrated systems are still being developed.

FORPLAN

Early in this century, following the European

forestry tradition, simple formulas were developed

to determine allowable timber harvest levels for the

unmanaged American forests with their large stocks

of old-growth timber. These formulas no longer

sufficed by the late 1950s, and computer models

were developed to assess the long-term sustainability of timber harvest levels. FORPLAN was an

outgrowth of these models, and also incorporated

various aspects of a land allocation model developed

for watershed analyses. FORPLAN is basically a

linear programming model that maximizes the

present value of resource uses and outputs (minus

costs) within the specified constraints. FORPLAN

includes absolute constraints (e.g., acres, productive

capacity, and targets or management requirements),

flow constraints (for assuring sustainable production

levels), and relational constraints (to specify relations among variables).

In December 1979, the Forest Service designated

FORPLAN as the principal analytical tool for forest

planning. The agency believed that consistency in

analytical approach was necessary, and FORPLAN

was chosen because it was available and addressed

some of the key questions in forest planning: the

allowable timber sale level under a policy of

long-term sustainability, and the lands available for

timber harvesting. This capacity of FORPLAN is

one of its strengths for forest planning. Another

strength is FORPLAN’s enormous analytical capacity; it can consider hundreds of thousands of possible

combinations of management prescriptions (combinations of management activities) and analysis

areas. FORPLAN also has required foresters, biologists, archaeologists, landscape architects, and other

specialists to translate their knowledge into a

common format, thus forcing them to learn a

common ‘language’ and encouraging real interdisciplinary efforts. Finally, some have asserted that

FORPLAN’s complexity has served as a barrier to

criticism, and thus has preserved local agency

discretion for forest management.

FORPLAN also has many weaknesses. Inherent

in linear programming is the inability to include risk

and uncertainty and the assumption that inputs and

outputs are direct, continuous, and reversible (i.e.,

that prescriptions and analysis areas are independent

of other prescriptions and areas, that inputs and

outputs can be adjusted in minute quantities, and that

there are no thresholds for ecological changes).

Furthermore, FORPLAN requires data on costs,

outputs, and the relationship to constraints for each

prescription and analysis area. Such data requirements substantially exceed the knowledge base for

many resources, including timber if uneven-aged

management is to be considered (as is required by

NFMA).
Chapter 7—Technologies for National Forest Planning . 139

The structure of FORPLAN carries important

implications for forest planning. The goal is to

maximize the value of uses and outputs, but many

uses and outputs are difficult to value because they

lack market prices to indicate their worth. More

importantly, nonuse values--e. g., protecting watersheds, preserving endangered species, improving

aesthetics, and other values of having viable ecosystems—are included only as constraints on the

uses and outputs. This structure implies that sustaining ecosystems is a constraint on production, and not

a goal for managing the national forests.

FORPLAN has some capacity to analyze spatial

considerations, but adding spatial data substantially

increases the size, complexity, and cost of the model,

FORPLAN is so large that sometimes even the users

do not understand why certain results occur; it is also

possible to manipulate the system and to hide

assumptions. Furthermore, the documentation of the

system and of the assumptions and data used has

been inadequate, preventing others from examining

the FORPLAN analyses. Parts of the system have

not been tested (verified), although sufficient monitoring of implementation could provide the testing

needed. (See ch. 6 for more on monitoring.)

The Forest Service has done a remarkable job of

acquiring the analytical capacity to use FORPLAN.

However, the difficulties in forest planning and the

lack of promotional potential is causing low morale

among analysts. The lack of clear understanding of

how analyses would be used in decisionmaking has

added to the dilemma. Managers have sometimes

used analytical results without understanding the

limits of the analysis. At other times, managers have

ignored the results because they did not trust the

system or the analysts. Better communication between analysts and management and with the public

is needed if FORPLAN is to be useful in forest

planning.

Options for the Future

FORPLAN will undoubtedly continue to evolve

and be used in forest planning. The agency has sunk

a lot of money into developing the system and in

finding and training the people to use it (23).

FORPLAN can provide useful information (13,

226), and it or a similar model is probably necessary

to analyze the sustainability of timber harvest levels

over long time periods. Furthermore, there are few

real alternatives to FORPLAN (179). Thus,

FORPLAN will continue to be used.

Although the use of FORPLAN in forest planning

could be improved, it cannot do all of the analysis

required for forest planning.

No approach will produce a perfect model of the

real world, because all models are abstractions which

necessarily are simplifications of reality (14).

Thus, FORPLAN should be linked to other systems.

The Forest Service is already using many resource

simulations for input to FORPLAN, but additional

development and more integrated use of simulation

models are needed (146, 234). A GIS is probably

essential to assure the spatial integrity of planning

alternatives, and a corporate database would provide

a consistent structure for the data needed in the

various analytical systems.

A more hierarchical planning structure could also

contribute to the use of FORPLAN in forest planning (72, 179). Some ecological modeling must

occur at large scales, other at much smaller scales

(172). Furthermore, FORPLAN has been devised to

try to answer all forest planning questions at one

time (14). The regulation requiring a timber sale

schedule in the forest plan has particularly contributed to the complexity of FORPLAN (179, 234).

FORPLAN could be substantially simplified, to the

point where users and outsiders could understand the

analysis, if more analysis was done before

FORPLAN was used (234) and if additional planning and tools were developed for forest plan

implementation (54, 146).

Finally, better communication about the results

and limitations of the FORPLAN analyses is essential. A simpler FORPLAN model under a hierarchical planning structure would help (14), but closer

connections between analysts and managers are also

necessary (61, 123), FORPLAN is a useful tool for

examining productive capacity and tradeoffs among

activities (13). These analyses should contribute to

public participation, rather than limit or prevent.
Chapter 8

Economics in National

Forest 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. **co .o.   e** eoeo ooeo*. oeo+* e

Determinin 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

143

143

144

145

147

148

148

151

151

151

152

154

156

156

158

158

Box Page

8-A. Valuing Nonpriced Goods and Services ... *e. *o. ..** coo. **** o*e***. ... .**o*e***. c . 145

8-B. Forest Service Trust Funds and Special Accounts ● . . . * . . . . . * . . * . * . . . . . * * * * . . . . . . . . . . 155

8-C. Peculiarities in Forest Service Payments to States . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 156

8-D. Timber Purchaser Road Credits *.. ..** *e. ..oo. *.. ..*. oooo. o.c. ... ..*. *ooo. ..** *.e. 157

Figure

Box Page

8-1. Receipts From Activities in the National Forests . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 152
Chapter 8

Economics in National Forest Planning

Economic considerations enter into the strategic

planning process for national forest management in

two ways: in evaluating the tradeoffs among the

values generated by the forests; and in identifying

the economic impacts of national forest management. This chapter briefly describes the Forest and

Rangeland Renewable Resources Planning Act of

1974 (RPA) and the National Forest Management

Act of 1976 (NFMA) requirements for economic

analysis, and then assesses the use of economics in

determining the management balance and in identifying the economic impacts. The chapter concludes

by analyzing the relation of the Forest Service

budget process to strategic national forest planning.

LEGAL REQUIREMENTS

RPA and NFMA substantially expanded the role

of economic analysis in Forest Service planning and

management (246). RPA requires: an Assessment

that analyzes resource supplies and demands and

evaluates investment opportunities; a Program to

identify investment needs and to compare outputs,

results, and benefits with costs; a Statement of

Policy to guide the formulation of budgets; and an

Annual Report to provide accountability for expenditures and activities, with appropriate measures of

relevant costs and benefits and with representative

samples of below-cost timber sales.

National forest planning must also include economic analysis. NFMA requires that economics be

integrated with physical, biological, and other sciences by the interdisciplinary team (section 6(b)).

Economic and environmental aspects of management are to be considered in planning for the

multiple uses (section 6(g)(3)(A)). Economic impacts, along with environmental, biological, esthetic, and engineering impacts, are to be reviewed

on each advertised timber sale using even-aged

silvicultural techniques (section 6(g)(3) (F)(ii)). Economic, physical, and other pertinent factors are to be

considered in identifying areas not suited for timber

production (section 6(k)). Road needs are to be met

on an economical and environmentally sound basis,

and road standards are to be appropriate considering

safety, transportation costs, and land and resource

impacts (section IO(a) and (c)).

This guidance in NFMA strongly suggests congressional interest in efficient Forest Service management. However, as discussed in chapter 3,

Congress is also concerned about fairness and

balance. NFMA clearly directs management in

accordance with the Multiple-Use Sustained-Yield

Act of 1960 (MUSYA), which requires the Forest

Service to “best meet the needs of the American

people. ” MUSYA also prohibits maximizing returns or outputs as the sole criterion for management, and NFMA adds that the timber harvesting

system is not to be chosen primarily to maximize

returns or outputs. Nonetheless, MUSYA also requires management ‘‘with consideration being given

to the relative values of the various resources. ’

Finally, although there is no explicit direction in law

to consider community stability in forest planning,

Congress has on numerous occasions clearly expressed concerns about the impacts of national forest

management on local communities.

THE BALANCE AMONG

RESOURCES

In MUSYA, Congress explicitly directed the

Forest Service to consider the relative values of the

various resources. This implicitly requires an economic evaluation, because the science and art of

economics focus on tradeoffs in values. Economics

generally concentrates on two issues: efficiency and

equity. Economic efficiency aims at minimizing

waste, generally by reducing the cost to produce a

given level of output or by increasing the outputs

from a fixed budget. Efficiency is no less important

for government agencies than for private firms, but

it is more difficult to achieve because the outputs are

generally less precisely measured.

Equity considerations center on questions about

the fairness and balance of activities, and about the

distribution of income and benefits. Historically, the

field of economics has emphasized efficiency. For

example, in their recent book on the economics of

multiple-use management, Bowes and Krutilla (31)

dismiss the distributional equity consequences of

public land management in one paragraph, and then

spend 300-plus pages on economic efficiency.

Efficiency has traditionally been emphasized because it can be measured and evaluated, while

–143–
144 . Forest Service Planning: Accommodating Uses, Producing Outputs, and Sustaining Ecosystems

unbiased measures of fairness and balance do not

exist. Nonetheless, equity-the fair distribution of

income and benefits--is one of the principal concerns of government.

As discussed in chapter 3 and noted above,

Congress did not accept efficiency as the principal

consideration for managing the national forests in

enacting MUSYA. Nonetheless, economic efficiency is not irrelevant. In the debate over NFMA,

Senator Dale Bumpers (Arkansas) expressed concern over ‘‘the problem of wasteful investment in

timber production.’ More recent debates over belowcost timber sales also suggest concerns about the

efficiency of Forest Service timber activities. The

Office of Management and Budget (OMB) is particularly concerned about the efficiency of government

spending (217). The magnitude and persistence of

the Federal budget deficit will make the efficiency of

government activities, including national forest

planning and management, a continuing concern.

Many economists, inside and outside the Forest

Service, believe that determiningg the balance among

resource uses, outputs, and protection is essentially

a question of economic efficiency-if uses and

outputs can be valued correctly and the interrelationships can be quantified accurately, the proper

balance can be determined by a simple economic

efficiency decision rule. Some have even argued that

economic efficiency should be the primary criterion

for forest plans:

If properly done, NFMA planning should be

nothing more than a series of cost-benefit analyses

that lead to economically optimal forest plans (309).

Economic Efficiency in

National Forest Planning

Efficiency is measured by examining costs and

benefits. Efficiency increases as costs to produce the

same benefits decline or as greater benefits are

generated at the same cost. In practice, improving

efficiency typically focuses on the cost side--the

appropriate budget level and proper mix among

activities. Neoclassical economic theory dictates

that the “correct” budget level and mix are defined

by the relation of costs and returns, with expenditures increasing as long as the returns are greater

than the costs; ultimately, the last dollar spent should

yield a return of exactly one dollar. (If the return is

greater than a dollar, more expenditures are warranted, but if the return is less than a dollar, too much

has been spent.) In technical parlance, the efficient

budget level is the level where the marginal benefits

equal the marginal cost for each activity; this defines

both the total budget and the efficient balance.

In the private sector, benefits are typically revenues, but a government agency often generates

social benefits from goods and services provided

rather than revenues. As noted earlier, many of the

uses and outputs of the national forests do not have

market prices. However, numerous techniques have

been developed to estimate the value of unpriced or

subsidized uses and outputs. (See box 8-A.) Calculated values can, in theory, be used as proxies for

social benefits. Thus, the neoclassical theory of

economic efficiency can still be used, if the value of

the goods and services (including nonuse values)

can be determined.

Investments complicate the comparison of expenditures and returns, because expenditures and returns occur at different points in time, and the value

of a dollar today is greater than the value of a dollar

tomorrow. (The difference in value is interest,

usually presented as an annual rate.) However,

expenditures and returns can be compared, if they

are adjusted for timing at the relevant interest rate.

(This rate is also known as the discount rate, and the

procedure is called discounting future costs and

returns to the present.) There are numerous methods

for comparing discounted expenditures and returns.

A common one, and the one used by the Forest

Service, is to subtract the present (discounted) costs

from the present (discounted) value of the returns to

determine the present net value of the investment.

The marginal approach of neoclassical economics is

not as useful, since investments are generally not

small changes. Nonetheless, a similar decision rule

exists: if the present net value is positive (if the

discounted returns exceed the discounted costs), the

investment is desirable.1

The Forest Service uses an economic efficiency

approach 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 ratiO

of discounted returns to discounted costs (the infamous benefit/cost ratio) is more useful to rank alternative investments, although a number of other

techniques (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 values

include not only today’s use, but the value of having the option to use the resource in the future (commonly known

as option value). Nonuse values include the value of knowing the resources exist as well as the value of preserving

the 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 on

the financial impacts of current use, usually by measuring either total expenditures or the value added because of

those expenditures. Except for evaluating local community impacts, this approach is rarely used, because it does

not measure the value of the resource. It would be like measuring the value of timber by tabulating how much timber

purchasers spent on labor, equipment, gasoline, etc.

The second approach is based on estimated demand for the resources. This approach is generally preferred for

its sound theoretical basis, but is more difficult to apply, because it requires demand curves. Methods have been

developed for calculating demand curves for recreation and other nonpriced uses and outputs, typically relying on

travel costs (the travel cost method) (210), on site attributes (the hedonic pricing method) (31), or on an artificially

structured bidding market (the contingent valuation method) (58). All such methods develop a demand curve

relating quantity demanded to various prices. Demand curves can also be developed for nonuse values using the

latter two methods.

Demand curves for nonpriced resources are usually used to calculate consumers’ surplus. Consumers’ surplus

is the total additional amount that the beneficiaries are willing to pay for the good or service, in excess of their current

expenditures. It is also described as the possible revenues of a perfectly discriminating monopolist (i.e., one who

could charge a different price to each customer). This is a useful measure, but may not be directly comparable to

market prices for commodities, since the market price is how much the buyers do pay, not how much they would

be willing to pay.

The Forest Service modified the traditional consumers’ surplus in the 1990 RPA Program (281) by estimating

the 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 supply

and 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 report

suggest that a single supply curve was used in all regions for many different activities. This approach is conceptually

strong, but additional information on supply curves is needed.

in national forest planning (246). FORPLAN is a suggest that the proper technique depends on the

computer model that maximizes the value of uses

and outputs while meeting specified constraints.

(See ch. 7.) The goal (technically, the objective

function) is to maximize present net value of

resource uses and outputs; thus FORPLAN fits the

neoclassical economic theory of economic efficiency.

Limitations of FORPLAN

in Achieving Efficiency

Resource Values

One difficulty with economic efficiently in forest

planning arises from the questionable comparability

of values for marketed and unpriced uses and

outputs. Substantial research efforts over the past 30

years have developed various techniques for valuing

unpriced resource uses and outputs. (See box 8-A.)

Researchers have defended various methods as the

best or most appropriate (31, 58, 210), and some

nature of the resource (242). Furthermore, the

comparability of market prices for commodities to

the calculated values for unmarketed or subsidized

resources has long been debated (154, 262). The

extent of the polemic over this issue indicates

substantial uncertainty over the comparability of

market prices for resource commodities with the

calculated values for unpriced resources. This limits

FORPLAN’s usefulness in examining the economic

efficiency of forest planning and management.

Another problem with using FORPLAN to assess

efficiency is that some values are not included in the

objective fiction. As discussed in chapter 7, the

objective function in FORPLAN only contains

values for uses and outputs. However, people also

value just having natural areas, protecting the

opportunity to use them in the future, and preserving

a legacy for future generations-values generally

known as option values, existence values, and
146 . Forest Service Planning: Accommodating Uses, Producing Outputs, and Sustaining Ecosystems

bequest values. These values are not included in the

FORPLAN objective function, and cannot be readily

assessed relative to use and output values. Instead,

nonuse values are expressed as constraints on the

objective function. This approach provides only the

selected level of protection for nonuse values; less

protection is not allowed, and additional protection

yields no additional benefits. Assessing the tradeoffs

between outputs and nonuse values is very difficult,

at best. Furthermore, considering nonuse values as

constraints, and uses and outputs as objectives,

suggests unequal treatment; uses and outputs are

benefits, but nonuse values are limitations on

national forest management.

Finally, even supposedly concrete values are

subject to considerable uncertainty. Off-budget funds

(see below) are often excluded from economic

analyses, and cost data used in RPA and in forest

planning may be inaccurate (217, 259). Timber

values are also subject to debate. One analyst has

noted that forest plans assume unrealistic future

timber prices (187); these prices are based on

projections using the Timber Assessment Market

Model, which is quite sensitive to assumptions about

future U.S. economic performance, wood use technology, and the like (259). The imprecision of cost

data and timber values limit the usefulness of the

efficiency analysis in FORPLAN.

Resource and Site Interactions

Another limitation to using FORPLAN to assess

the efficiency of forest management alternatives is

that current knowledge about physical, biological,

social, and economic interactions among the resources is rather limited. For example, efficiency is

the essence of the debate over below-cost timber

sales. The Forest Service asserts that timber sales

can generate nontimber benefits, and that modifications to generate such benefits often increase costs

and/or decrease receipts, but that the sales are the

most efficient means to achieve the benefits (222).

Critics charge that the Forest Service not only loses

money on below-cost sales, but that timber sales

often damage, not benefit, the other resources (153,

187, 327). However, the cost to generate the desired

nontimber benefits without removing the timber

(e.g., cutting the trees and letting them decay) has

rarely been examined. Similarly, the possibility of

greater efficiency in the timber sale process has not

been analyzed. Thus, the below-cost timber sale

debate is being conducted with incomplete information on all sides. Such fragmentary understanding of

the effects of activities on resources and ecosystems

limits FORPLAN’s capability to analyze the efficiency of alternatives.

A related difficulty is the meager data on the uses

and outputs of noncommodity resources. While

timber harvests are measured, to charge for the

timber removed, recreation and other noncommodity uses and outputs are often estimated.

Annual recreation use figures are notorious among

field officials for being based on “a horseback

estimate’ of increase or decrease from the previous

year’s level, a figure which itself was based more on

a manager’s rough sense of use than on any direct

quantitative measurement (217).

Thus, imprecision in the existing data, as well as the

lack of understanding of resource interactions,

restrict the capacity of FORPLAN for efficiency

analysis.

The analysis of economic efficiency is further

complicated by site interactions, because the management of one site may affect the efficiency of

activities on other sites (138). For example, constructing a road might be an efficient means of

providing access to two adjoining stands of timber

if both areas are managed to produce timber, but

might not be an efficient use of resources if only one

area is producing timber. Management efficiency of

various sites is most likely to be interdependent

when access (principally road construction) is a

significant portion of the management costs. However, the shortcomings of FORPLAN for addressing

site-specific issues also limit its capability to assess

the efficiency of interdependent management decisions.

Inefficient Prescriptions

Many critical decisions about balance and efficiency are decided before FORPLAN is used (30). In

particular:

Decisions about suitable timberlands, the allowable sale quantity of timber, wilderness, unpriced

outputs such as scenic and wildlife resources,

silvicultural systems and land allocations are strategic elements of a forest plan that are generally

decided outside a FORPLAN analysis, using subjective evaluations that reflect considerations other than

economic efficiency (246).

Among the principal inputs to FORPLAN are the

management prescriptions-the general manage-
. —— — . . . . . . . .

Chapter 8--Economics in National Forest Planning . 147

ment practices that are proposed for an area over

time. If timber is to be harvested, the prescription

would specify the rotation (harvest) age and the

silvicultural system to be used, the reforestation

practices, and any intermediate stand treatments,

before the harvest and/or after successful reforestation. Prescriptions would also identify other activities expected in the area, such as wildlife habitat

improvements, recreation developments, range improvements, and erosion control.

The timber industry has argued that the Forest

Service’s timber management prescriptions are inefficient, that different systems could yield greater

timber benefits and still protect the other values

(308). However, while research has examined the

costs and benefits of specific activities, very little

has been written about management prescriptions

and economic efficiency (123).

Forest Service research has shown that many

timber sales are modified to mitigate or enhance

other resources, often increasing costs or reducing

revenues (19, 182, 223). Comparing the efficiency of

various management prescriptions can be done

under a patchwork dominant-use management framework (as described in ch. 3), because the outputs of

the dominant resource can be compared to the

management costs (assuming that the environmental

quality and resource conditions standards are still

maintained). However, assessing efficient prescriptions under integrated resource management is

difficult because it requires an accurate understanding of the quantity and quality changes in all

resources that result from a management activity

(31, 221). Such knowledge, as well as measures of

quantity and quality for all resources, is currently

lacking.

Investment Commitments

Government agencies generally do not distinguish between capital and operating expenditures.

Annual budgets and appropriations generally contain no special provisions for addressing capital

investment needs. However, separating these costs

from operations and maintenance is necessary for

efficient investment, especially ‘ ‘if future expenditures [such as timber stand improvements] are tied to

present investment decisions [such as reforestation]” (3 1). Mixing capital and operating expenses

can contribute to inefficiency; future investments

might be poorly timed, if they are made at all.

However, Congress is reluctant to commit itself to

fund future investments, regardless of the efficiency

of such investments. Political realities thus inhibit

the management efficiency that FORPLAN shows to

be feasible.

Determining the Balance: An Equity Issue

The technical limitations of FORPLAN are not

the only reason why economic efficiency is not used

to determine the proper management balance for the

national forests. Observers have noted the public’s

general lack of interest in economic efficiency for

Federal land management (138), and even a philosophical opposition to efficiency standards:

Even supposing that the measurement problems

could be miraculously overcome, it would not

change the fact that the benefit-cost analysis is a

direct descendent of utilitarian principles and thus

philosophically unacceptable to a growing segment

of the American public (164).

Using efficiency to determine management is also

problematic in that the beneficiaries of government

activities often do not pay the costs (44). Hunters,

hikers, off-road vehicle users, and arguably even

ranchers and loggers often do not pay the full cost for

the benefits they receive. This is the essence of the

argument set forth by those who advocate market

solutions for management problems, However, Congress rejected this approach in national forest

management. Determining the mix of uses, outputs,

and protection is more a question of balance and

fairness-equity-than one of efficiency.

The Forest Service has implicitly recognized that

efficiency alone cannot determine the acceptable

management direction for the national forests. Although FORPLAN compares alternatives for a

national forest, the preferred alternative (and the

final forest plan) is rarely the one that maximizes

efficiency, as defined by present net value. Nonmaximum selections by Forest Service line managers

essentially acknowledge that computer models probably cannot choose a balance among resource uses,

outputs, and protection that is acceptable to the

public.

How, then, can balanced management be established in forest planning? As discussed in chapter 5,

Congress intended the Forest Service to determine

the proper balance by listening to the public. This

does not imply public decisionmaking, but that the

agency discuss goals, opportunities, and limitations

with affected and interested individuals and groups.
148 ● Forest Service Planning: Accommodating Uses, Producing Outputs, and Sustaining Ecosystems

Through such interaction and deliberation, the

agency can learn about the public’s desires and

values, about new possibilities and practices for

efficient and effective production and protection,

and about the use and output levels the public finds

acceptable. Members of the public can listen and

learn about their own and each other’s desires and

values, fostering cooperation, rather than enmity.

This is not to suggest that such discussions can lead

to agreement on all issues. At times, the Forest

Service must make hard choices. However, balance

can only be achieved through meaningful interactions among the agency and various public interests.

IMPACTS OF NATIONAL FOREST

MANAGEMENT

Decisions about national forest management affect not only direct users, but also local communities. Congress has also shown concern for community stability and the effects on counties of the tax

exempt status of national forest lands. These concerns, and efforts to address them, affect strategic

planning for the national forests. The policy of

sustained yield for stable timber harvests is based on

providing stability for communities. Much of the

debate over the economic impacts of national forest

management has focused on the effects on the timber

industry. The following discussion follows this

emphasis, but it is not intended to suggest that the

effect on other sections of local economies are

unimportant. The difficulty of assessing such effects

is also discussed.

Community Stability

Concern and Approach

Congressional concerns about the impacts of

Federal land management on communities date back

at least to the 1897 Forest Service Organic Act. The

floor debate over the purposes for which forest

reserves could be established strongly indicates the

congressional interest in making timber available to

citizens (233, 326). Some have argued that Congress

has clearly directed national forest management to

consider community stability (185). Others assert

that the congressional commitment to community

stability is far less clear (218), that while local

planning under NFMA includes community stability, national planning under RPA virtually precludes

considering it (219).

Regardless of the clarity of congressional commitment to community stability, the concern is real.

However, the legislative direction for the Forest

Service to consider community stability is ambiguous, at best (193). Nonetheless, as a strategic

planning process, NFMA planning is to address

issues and concerns, and community stability is

often raised as a local concern (225). Thus, community stability must be considered as an issue in the

forest planning process.

Impacts on communities are typically assessed in

forest planning using IMPLAN--a multicounty

input-output model adapted to each national forest.

(See ch. 7.) Input-output analysis relies on a general

equilibrium model of the economy, with quantitative relationships to describe the interactions among

various manufacturing, service, and other sectors. A

demand-driven input-output model, such as IMPLAN, estimates the impact of changes in national

forest uses and outputs on employment and local

income; it has the ability to separate the direct

impacts on one sector from the indirect and induced

impacts on other sectors. Thus, IMPLAN can

display the local economic consequences of various

management alternatives for the national forests.

Limitations

Despite congressional and local concern for

community stability, the Forest Service has limited

ability to assess and to achieve community stability.

Assessing Community Stability-one difficulty

in addressing community stability stems from the

imprecise definitions of community and stability

(157, 218). There is no legal definition of, or

requirement to manage for community stability

(193). Furthermore, academia has also struggled

with these concepts.

The first three speakers [at a 1987 conference on

community stability (150)] were an economist, a

sociologist, and a lawyer. They said, essentially, we

can’t measure community stability, we’re not sure

what it means, and the Forest Service has no legal

authority to do anything about it. In response, at

lunch, a Forest Service spokesman said yes, that

might all be true, but the Forest Service is going to

“do community stability anyway” (224).

Economists generally define communities based

on their distinctive economic functions (236). Sociological definitions typically include both geographic

and cultural elements. “Community” can also be
Chapter 8--Economics in National Forest Planning ● 149

defined by social relationships and interactions, or

by a shared identity (145). This latter aspect is

particularly important for some groups, such as

loggers (40). Small rural communities are often

assumed to fit the definition on all counts, but such

is rarely the case ( 145). Newcomers frequently bring

different styles and cultures to these communities

(230); however, these do not always conflict with the

long-term residents of rural areas (26). What all this

means is that there is no simple definition of

community that can be used for estimating and

reporting the effects of national forest management

on ‘‘communities.’

Stability is equally difficult to define, but typically is measured in economic terms-jobs, income,

prices, and the like (157, 169). This is important

information, to be sure, but not the full measure of

a community’s stability. However, quantitative measures of social stability do not exist. Furthermore,

stability is often equated with maintaining the status

quo, but most recognize that change is an essential

part of long-term stability, that communities are

dynamic (218, 236). The difficulty lies in trying to

determine the amount and pace of change that

affords stability-too much or too fast is unstable,

but too little or too slow results in stagnation. The

difficulty in measuring the amount and pace of

change and the lack of measures of social stability

limit our ability to assess the stability of communities.

Input-output analyses have two additional shortcomings for assessing community impacts. First,

economic sectors are reported by county, but the

resulting data can mask local variations within a

county. For example, Montana’s Gallatin County

contains both timber-based communities (Gallatin

Gateway and Belgrade) and recreation towns (West

Yellowstone and Bozeman); similarly, neighboring

Park County has one town dominated by a sawmill

(Livingston) and another dominated by the tourist

trade (Gardiner). Thus, using county data may not

provide an accurate picture of the impacts of national

forest management on individual communities.

In addition, the economic data used in inputoutput analyses do not provide comparable details

for all resource-based sectors of the economy. The

U.S. Department of Commerce defines lumber and

wood products as a separate manufacturing industry.

In contrast, forestry and livestock production are

part of agriculture, while recreation is scattered

among a host of industries generally classified as

retail trade or as services. Expenditure profiles can

be developed for each type of recreation to get

recreation employment and income data comparable

to timber employment and income data (191), but

the task is costly and time-consuming. Thus, existing data on economic interactions provide a more

thorough picture of the impacts of national forest

management on the timber industry than on other

industries that may also rely on the national forests.

Achieving Community Stability--The forest management policy of sustained yield for a stable timber

supply has long been justified on the grounds that it

promotes community stability (219). Thus, community stability has often been equated with timber

industry stability (8, 236). While there is broad

recognition of the importance of other resources to

certain communities, much research and concern

still concentrates on the stability of communities

whose economies depend on producing wood products from national forest timber.

To date, no empirical evidence has shown that

stable timber production leads to stable communities

(62, 69, 93), and some studies suggest that timberdependent communities may be less stable than

other communities (97, 311). A broad array of

factors affect the demand and supply of wood

products, and the stability of local wood supplies is

but one of these (193).

Researchers have found that the cyclicality of the

timber industry has led to a certain community

response to distress-a passive expectation that

conditions will eventually return to normal (40).

This, however, can lead to a loss of local leadership

that could help the community adjust to upheavals

(1 15). In addition, a mill closure alters the structure

of a community quickly and substantially, further

limiting its ability to respond (314).

The Forest Service has recognized the difficulties

associated with defining and achieving community

stability. Thus, its community-stability goal has

been defined as that of preventing sudden, catastrophic instability when possible by gradually

phasing in changes, thus minimizing economic and

social impacts. According to Associate Chief

George Leonard (151), “community stability means

the avoidance of radical, or abrupt, changes in the

economic or social structure.
150 . Forest Service Planning: Accommodating Uses, Producing Outputs, and Sustaining Ecosystems

This suggests that community evolution may be a

more apt goal than stability. Darwinian evolution

occurs through the accumulation of small, gradual

changes. However, an alternative view of biological

evolution (known as punctuated equilibrium) suggests that species may evolve quickly, then remain

quite stable for long periods before disappearing

quickly (73). This alternative view—long periods of

stability interrupted by abrupt changes—may also

be more descriptive of community evolution.

Rural communities frequently depend on one or a

few industries or firms; economic changes (regional,

national, and/or international) may cause severe

local distress and upheaval. A sawmill, for example,

may be able to adjust production levels, but it cannot

close gradually. The national forests accommodate

uses and produce outputs, but the Forest Service

cannot control the economic factors that determine

a fro’s ability to stay in business. With limited

responsibility and limited means, the agency clearly

has limited ability to promote community stability

(61). Perhaps the best that can be hoped is to not be

the cause of major distress, as the Forest Service has

suggested.

At the 1987 conference on community stability

(150), a Bureau of Land Management (BLM)

employee questioned the extent of the industry’s

responsibility for community stability (175):

What is the timber industry’s role and responsibility in community stability? . . . Specifically, for

those companies with a land base, to what extent

should their harvest scheduling consider community

stability, especially in light of projected future

shortfalls? For those companies with no land base, or

no merchantable volume of lumber, how should the

company consider future investments, especially to

expand production capabilities, considering community stability in the long run? Recognizing that many

companies are active, positive members of the

community (while they are there) who make numerous contributions to the community ..., what is the

timber industries [sic] larger role in community stability?

In other words, can the Federal Government be

responsible for community stability when the private sector cannot be compelled to ignore market

signals in making timber harvesting and mill capacity decisions that affect short- and long-term community welfare? Can, and should, the national

forests insulate communities from decisions in the

private sector? And, what about communities that

have grown largely in response to Forest Service

efforts to develop a timber industry in certain areas

(291)?

Implications for National Forest Planning

The impact of national forest management on

local communities is an issue that must be addressed

in national forest planning. Although the congressional direction for considering community stability

is imprecise, the Forest Service is to be responsive

to public concerns in the planning process, and the

public is often concerned about the very real impacts

of national forest management on communities.

Thus, as the Forest Service has recognized, the

community stability issue cannot be ignored.

Because of the agency’s inability to control future

economic conditions, it is probably infeasible to

assure community stability. Nonetheless, the Forest

Service should disclose a full picture of the likely

economic and social consequences of alternative

actions considered in the planning process. Current

plans rarely display all financial information+. g.,

government revenues, expenditures (including those

financed from revenues), and receipt-sharing payments—and often do not discuss impacts that occur

away from the forest-e. g., on downstream fisheries

and municipal and industrial water users (225).

IMPLAN provides a beginning (and will produce

a more complete picture as the Forest Service

specifies the various resource-related sectors more

fully), but is not sufficient to display the full suite of

ramifications of national forest management. First,

the Forest Service must not view the national forests

as the only source of resource uses and outputs; other

landowners can also provide the various uses and

outputs. In the planning process, the agency must

consider the actions of other landowners (including

neighboring national forests), and explore the opportunities to support them.

Furthermore, the Forest Service must also consider specific businesses that wholly or substantially

depend on the national forests (e.g., ranchers with

grazing allotments, certain sawmills, and outfitters

and guides who rely on Forest Service backcountry).

In particular, the Forest Service must examine the

extent to which a management alternative might

threaten the dependent business. The agency must be

aware of and sensitive to the businesses’ minimum

operating needs. This requires close cooperation

between the agency and dependent businesses, but
Chapter 8--Economics in National Forest Planning . 151

the Forest Service must also be careful to avoid

making decisions behind closed doors. Such “backroom deals” would harm the agency’s credibility

with others interested in national forest management.

Payments to Counties

Since 1908, the Forest Service has returned 25

percent of its receipts to the States for use on the

roads and schools in the counties where the national

forests are located; these payments are variously

called payments to States, payments to counties, and

Forest Service receipt or revenue-sharing.2 These

payments originated in 1907 (at a 10 percent return)

to compensate counties for the nontaxable status of

Federal lands and to encourage western development. (Other Federal lands were also not taxable, but

public domain lands were available for homesteading and other land disposal programs, and thus were

expected to become taxable at some point.) The rate

was increased to 25 percent in 1908, and the money

was permanently appropriated (i.e., the payments

would be made unless Congress acted to stop them).

However, there is no discussion in the Congressional Record as to why 25 percent was deemed the

appropriate compensation for counties.

Forest Service 25-percent payments are often very

important to counties. They are not the only compensation paid to counties for the local influence of the

Federal presence, but they are the only payments

affected directly by national forest management.

Furthermore, in some heavily timbered counties in

the Pacific Northwest, Forest Service payments

account for more than 80 percent of county operating

budgets (217). Thus, counties are very interested in

maintaining or increasing Forest Service receipts

(and the resulting 25-percent payments).

Timber receipts account for about nearly 95

percent of total Forest Service receipts in most years

(298). The dominance of timber receipts, combined

with the importance of Forest Service county

payments, often makes the counties proponents of

Forest Service timber sales, even at the expense of

other resources and industries (217). However,

timber receipts also fluctuate widely, often changing

by 50 percent or more from one year to the next

(298), and are much more variable than other Forest

Service receipts. (See figure 8-l.) Thus, under the

current system of compensating counties for the tax

exempt status of national forest lands, counties have

little certainty about their annual payments (and

hence, their budgets). Still, they are more likely to

support Forest Service timber sales than other

activities in the planning process.

FOREST PLANNING AND

THE BUDGET PROCESS

The annual Forest Service budget has a substantial affect on national forest management. Budgets

determine implementation of strategic plans, and

provide centralized control over planning by an

organization’s units. In forest planning, the budget

effectively controls plan implementation. The Forest

Service budget is also the direct link between

Congress and national forest management. This

section explores the relationship between forest

planning and the Forest Service budget by:

1.

2.

3.

describing how budgets are considered in forest

planning,

explaining how planning and the annual budget

process are linked, and

discussing how funding mechanisms outside

the annual budget process affect forest planning

and management.

The Budget Level in Forest Plans

Economic efficiency is clearly related to the

budget level. As described above, neoclassical

economic theory provides an approach for determining efficient budgeting if enough information exists.

However, because of the difficulty of measuring and

valuing many government goods and services, such

calculations are virtually impossible. Thus, the

budget level for each agency and program is

determined by political debate and ‘‘horse-trading”

to achieve a budget level and governmentwide

balance that meets the needs of the American people.

There has been an ongoing debate about whether

budgets should be constrained in developing Forest

Service plans (both forest plans and the RPA

Program) (51). The Forest Service argues that

budget 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, but

are reduced by other revenue-sharing programs. NationaJ forest lands are included in the entitlement acres for PILT payments, and the payments are

reduced by Forest Service revenue-sharing, but PILT payments are in auliirion fo the Forest Service’s 25-percent payments.
152 ● Forest Service Planning: Accommodating Uses, Producing Outputs, and Sustaining Ecosystems

Figure 8-l-Receipts From Activities in the National Forests (in millions of dollars)

Millions of dollars

1,000

1

4’ ‘,

/

/

\

#

/

I

I

I

b

600 % I

‘1 I

\ ?. I

\ 1-

\

400 \

\

\

200;

\/,“’” =

0! I I 1 I 1

1977 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 and

opportunities for resource management, and that

Congress and the public want to know the professionals’ estimate of the money needed to do the job

right (214).

However, unconstrained budgets typically amount

to “wish lists” (215). In the past RPA Programs, the

Forest Service has often implied that, with enough

money, they can solve all resource conflicts (147).

Furthermore, Congress and the public need information on priorities, on what activities should occur if

funding is limited (214, 259). Realistic budget levels

are particularly important for forest plans. The

public has spent much time and effort contributing

to the plans, and some view the goals and targets in

the plans as essentially moral commitments or social

contracts (136). If funding is substantially lower

than was planned, this contract cannot be fulfilled.

Furthermore, substantially lower funding may alter

implementation of the planned activities enough to

require that the plan be revised.

Both unconstrained and realistic budget information is clearly useful in planning, but the Forest

Service Washington Office gave little direction to

the forests on the budget levels to be used in forest

planning. One regional office directed the forests to

constrain the budget levels used in planning, while

others gave no direction. On some forests, planned

budgets were constrained by past budgets, but on

other forests, the plans were prepared without any

budget limitations-whatever money was needed

was assumed to be available. Thus, the budgets in

forest plans cannot be simply aggregated to a

National Forest System budget proposal; the budget

assumptions differ too much (215) and may not

reflect national fiscal priorities.

Plans and the Budget Process

The Current Budget Process

While NFMA directs that the integrated land and

resource management plans be prepared by interdisciplinary teams, the Forest Service’s annual budget

is not integrated. The House and Senate Committees

on Appropriations use more than 50 line items for

the Forest Service budget, with each line corresponding 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 done

by resource.

Projects under the integrated NFMA plans are

aggregated into budget proposals at each national

forest, and then the forest budgets are aggregated at

the regional offices; integrated resource management is translated into budget line items along the

way. The functional budget is modified first by the

agency’s Washington Office, then by the Office of

the Secretary of Agriculture, the Office of Management and Budget, and the House and Senate

Committees on Appropriations to meet the political

expectations and priorities of each of these participants in the budget process (217). However, the

integrity of multiple-use management under integrated forest plans is completely lost in this process,

and any relationship between the actual appropriations and integrated resource management is coincidental (138).

The annual appropriations, along with specified

output targets,3 are allocated among the regions, and

then to the national forests. Allocations are closely

tied to specific resources. The translation of line item

appropriations back into integrated management is

“done on an ad hoc basis by the resource managers

themselves out there on the individual ranger

districts” (215).

Allocated funding and output targets thus become

the management guidance for on-the-ground management. The accounting for expenditures must, by

law, match the appropriations; managers can be held

personally responsible for the misuse of Federal

funds. The Forest Service does have some authority

to transfer funds among programs (technically

known as reprogramming), but reprogramming has

limited use because:

1. the authority is for relatively limited amounts;

2. the process is time-consuming, but the need

may not be known until the field season is

under way, late in the fiscal year; and

3. conventional wisdom holds that if money is not

used, it wasn’t really needed, and won’t be

available again (i.e., ‘‘use-it-or-lose-it’ (215).

Problems and a Possible Solution

The result of line item appropriations and limited

reprogr amming opportunity is that expenditures are

often reported as they were planned, not necessarily

as the money was actually spent (215, 217, 254).

Thus, the accounting data may not reflect the way

funds were spent managing the various resources.

Some of the inaccuracies are intentional, but the

imprecision of translating line items into integrated

resource projects and then trying to accurately

allocate time among the resource line items is the

principal culprit (217).

This cost-accounting problem is compounded by

inaccuracies in reporting target accomplishment.

For commodities (especially timber), the targets are

readily measurable, and must generally be met. For

other resources, however, the methods for measuring and reporting outputs are less precise and less

tangible; watershed accomplishments, for example,

are more related to the size of a watershed than to the

effort expended (215). (See ch. 6.) As a result, there

is ‘‘no recognizable relationship between variations

in funding and variations in output” (215). Thus,

under the current system of line-item appropriations

and accomplishment reporting, Congress and the

American people do not really know what they are

ultimately buying when money is appropriated for

national forest management.

To eliminate these problems, the Forest Service

has proposed an alternative budgeting system, known

as end-results budgeting. Under this approach, the

line items for national forest management would be

collapsed into one operations and maintenance

account; separate line items would be retained for

investments in roads, trails, and facilities, for

reforestation and timber stand improvement, and for

land acquisition (215). The General Accounting

Office (GAO) (251) was favorably impressed with

the agency’s test of end-results budgeting, finding

that expenditures were reported more accurately and

that more outputs were being produced without

increasing costs.

End-results budgeting is not without its problems.

Congress may fear losing control over the budget for

each resource program, although this fear is unrealistic, 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 Service

Washington Office, based on the enacted appropriations for that resource.
154 ● Forest Service Planning: Accommodating Uses, Producing Outputs, and Sustaining Ecosystems

control now if expenditures are reported as planned.

Nonetheless, the softness of output measures for

noncommodity resources could lead to increased

focus on the hard, measurable output targets. (See

the discussion of monitoring in ch. 6 and of

performance appraisal in ch. 9.) Wilderness, for

example, is measured in acres managed, a function

of Congress’s designation, not of managerial performance. For end-results budgeting to work, accurate measures are needed for changes in the quantity

and quality of all resources resulting from management efforts (215, 259).

“Off-Budget” Funding

Special Accounts and Trust Funds

The Forest Service has a number of special

accounts and trust funds that are independent of the

regular, annual appropriations process. (See box

8-B.) Not all special accounts and trust funds are

‘‘off-budget’ some require annual appropriations

from Congress to allow money from the account to

be spent. However, for several special accounts and

trust funds, Congress permanently appropriated

adequate funding when the fund or account was

created. 4 The Forest Service has 14 permanently

appropriated special accounts or trust funds, 7 with

annual expenditures exceeding $10 million. In 1987,

permanent appropriations amounted to more than a

third of the Forest Service budget for the National

Forest System (297).

The funding for six of these major permanent

appropriations is largely or entirely related to the

timber program. As described above, the Forest

Service returns 25 percent of its receipts to the States

for use on roads and schools in the counties where

the national forests are located, and timber usually

accounts for 95 percent or more of total receipts.

(See also box 8-C.) Deposits to the KnutsonVandenberg (K-V) Fund are a portion of timber sale

receipts, while brush disposal and other cooperative

deposits are predominately deposits from timber

purchasers for work necessitated by timber harvesting, and the Timber Salvage Sale Fund receives

receipts from designated salvage sales. Finally, the

Reforestation Trust Fund uses tariffs on wood

imports (principally on imports of softwood plywood from Canada) to eliminate the backlog of

needed reforestation and timber stand improvement

work.

The Forest Service has substantial discretion to

determine the amount of money deposited in four of

these funds-K-V, salvage, brush disposal, and

other cooperative deposits. The agency determines:

1. the portion of timber receipts deposited in the

K-V Fund;

2. whether a sale is officially a salvage sale, with

receipts deposited in the Salvage Sale Fund;

and

3. how much timber purchasers deposit for brush

disposal and other cooperative work.

There are virtually no limits on the collections.

Deposits to the K-V Fund, for example, accounted

for more than 99 percent of timber receipts on the

Beaverhead National Forest in 1987, and more than

90 percent of timber receipts on eight other forests

(298). Nationwide, nearly 20 percent of timber

receipts were deposited in the K-V Fund in 1987,

including more than $9 million on the Klamath

National Forest (47 percent of the forest’s timber

receipts) and more than $8 million on the Tahoe

National Forest (55 percent of the forest’s receipts)

(298). Deposits for brush disposal and other cooperative work are generally less than deposits to the

K-V Fund, but still ranged as high as $7 million each

on the Willamette and Mt. Hood National Forests in

1987 (298).

All four of these funds must be used on the

national forest where the money was collected

(except for the portion allocated to overhead in the

regional and Washington offices). Thus, at each

national forest, the Forest Service has substantial

discretion for determining a large share of its budget,

if it has timber to harvest. A distinction is often made

between ‘‘rich” forests and “poor’” forests (217).

Rich forests simply have more timber available

and therefore more special account or trust fund

money—than poor forests. (See also box 8-D.)

Within each national forest, the Forest Service

also has discretion over how to spend the permanently appropriated funds. Timber salvage funds are

limited 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 these

appropriations when considering the Federal budget. However, permanent appropriations occur unless Congress acts to alter therq and are generally

excluded from discussions by the House and Senate Appropriations Committees and from their committee reports. Since Permanent appropriations occur

outside the regular annuat appropriations process, they are discussed here as ‘‘off-budget” iterns.
Chapter 8--Economics in National Forest Planning ● 155

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 with

permanent 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--National

Forest Roads and Trails Fund-has been effectively eliminated by the House and Senate Committees on

Appropriations since 1982, because these funds have been transferred to the U.S. Treasury to offset annual

appropriations for road and trail construction and maintenance. In addition, a 15th permanent appropriation-the

Tongass 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 of

1990 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. The

Working Capital Fund is at most indirectly linked to timber, since it is essentially a means of apportioning

equipment and other capital costs among the various forest management activities. The one major ($10 million or

more) 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 the

trust fur@ while interest on special account baknccs accrues to the U.S. Treasq. There is no difference in the means of finadng or in the

authority of the agency to spend money from the account.

sales, while brush disposal and other cooperative productive timberland in western Oregon. While it

deposits are only available for the specified tasks

that require money to be deposited. However, K-V

Funds are available for reforestation, timber stand

improvement, or other activities within the timber

sale area. In 1990, 53 percent of K-V Funds ($116

million) were used for reforestation, 14 percent ($30

million) for timber stand improvement, and 33

percent ($71 million) for other programs (287).

These other programs can include rehabilitation,

maintenance, or improvement of watersheds, wildlife habitats, and other resources. Thus, not only

timber managers have an interest in the collections

and use of these permanent appropriations; this is

particularly true of K-V Funds (124, 187).

Implications for Planning and Management

Are permanent appropriations necessary to accomplish various timber management and sale

activities? The answer is unclear. The Bureau of

Land Management (BLM) in the Department of the

Interior manages about 2 million acres of highly

must accomplish many of the same tasks as its sister

agency, BLM has no K-V Fund, no authority to

require deposits for brush disposal or other activities, and no purchaser road credits (291). BLM funds

road construction and certain timber management

activities through direct congressional appropriations or through uncompensated requirements on the

purchasers. The productivity and ownership patterns

of the lands might make such funding mechanisms

adequate, but BLM has demonstrated that such

programs may not be necessary to manage lands and

sell timber.

No evidence has been presented to show that the

permanent appropriations are efficient (for the

Forest Service or any other agency). Because the

money is available without action by Congress or the

administration, permanent appropriations are rarely

reviewed. Also, as noted earlier, permanent appropriations are typically excluded from analyses of

Forest Service efficiency, and even from reports of
156 ● Forest Service Planning: Accommodating Uses, Producing Outputs, and Sustaining Ecosystems

Box 8-C--Peculiarities in Forest Service

Payments to States

In 1976, Congress amended the1908 Act establishing permanent appropriations to return 25

percent of Forest Service receipts to the states for

use on roads and schools in the counties where the

national forests arc located.The counties were

concerned that the Forest Service was using timber

receipts to pay for reforestation and road construction (see box 8-D, below), thereby redwing the

payments tocounties . Therefore, Congress defined

Forest Service gross receipts to include certain

reforestation funds (i.e., deposits to the KnutsonVandenberg or K-V Fund) and timber purchaser

road credits. on forests with low timber values,

these ’’receipts” are often the majority of the timber

value; for example, deposits to the K-V Fund

accounted for 99 percent of timber receipts on the

Beaverhead National Forest in 1987 (298). In such

situations, Forest Service payments to counties and

deposits to the K-V Fund exceed the cash timber

receipts, effectively requiring transfers of funds

from forests with higher timber values. While the

Forest Service has always had sufficient cash

timber receipts to cover county payments and K-V

Fund deposits nationally, a number of frosts

require additional funds to meet these two cash

requirements-28 forests (8 in the Northern Region, 10 in the Intermountain Region, and 10

others) with a total transfer of $2.4 million in 1987

(298). However, this interregional transfer is well

hidden in the Forest Service budget.

Forest Service expenditures. However, the substantial local discretion over the level and use of these

funds prevents Congress from exercising full control

over the Forest Service budget. Some might argue

that Congress should have limited opportunity to

tinker with Forest Service funding; the earlier

discussion and analysis of end-results budgeting

suggest the benefits and problems of greater agency

fiscal autonomy. Nonetheless, whether permanent

appropriations are an efficient and appropriate

means of funding Forest Service activities remains

unclear.

Forest Service permanent appropriations undoubtedly affect national forest planning. As described

above, forest supervisors have little direct control

over their annua1 budgets for implementing the

forest plans. However, they do control the funds

available from the permanent appropriations. Furthermore, because at least the K-V Funds are

available for a variety of tasks, employees in many

resource specialties have a budgetary interest in

supporting timber sales. Some critics have even

suggested that Forest Service management is driven

primarily by efforts to the budget (124,

187). The use of K-V and other funds on some

forests does lend credence to this view, but managers

on other forests apparently rely much less on these

funds. Thus, budget maximization is certainly not

the sole motive of Forest Service employees. Nonetheless, budgetary considerations do support an

internal interest in maintaining or expanding the

timber sale program in national forest planning.

SUMMARY AND CONCLUSIONS

Economic considerations enter national forest

planning primarily as concerns about the balance

among resource values, about management efficiency, and about the impacts of national forest

management on communities. RPA and NFMA

require various economic analyses, and MUSYA

directs management to consider ‘the relative values

of the various resources. ” These laws clearly

indicate that efficiency is an important consideration, but not the principal criterion for management

decisions.

The Balance Among Resource Values

Some have suggested that efficiency is the appropriate standard for determining the balance among

resource outputs and environmental protection. Efficiency is generally evaluated by comparing benefits

(social benefits generated by a government agency)

with costs (including nonfinancial costs). To analyze

investments, current and future benefits and costs

are compared by calculating the present net value of

the investment. The Forest Service uses a computer

model--FORPLAN--for such analysis. As described

in chapter 7, this model maximizes the present net

value of the specified objectives, subject to various

constraints.

FORPLAN is a useful tool for examining the

efficiency of management alternatives, but has

limited capability to determine the most efficient

management balance. First, many uses and outputs

of the national forests are not marketed, and the

existing techniques for valuing unmarketed uses and

outputs might not provide values that readily compare to market prices. Furthermore, the FORPLAN

objective function includes only uses and outputs;

nonuse values of the forest (option, bequest, and
Chapter 8--Economics in National Forest Planning ● 157

%rcha?m insuchdtmtiom are also lea likely to face compedtioninbidding forl&ust Service tirober, however, and the fewer bidders

genelally lmalla ~ov~~~a relative price advantage. McbserS an mill poorer timk and face hi@H Opeming costs

without ncmsdly being less profitable

% aach Ml@iOns,-can bid up timber pricea by * amount of the ineii’e credib Witkut hcreamg“ thelqrlked cash

pymalta. 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 on

the Us. melwlly.

existence values) can only be included as constraints In addition to these limitations on using efficiency

onuses and outputs. FORPLAN analyses are only as

good as the information in the model, and thus are

restricted by incomplete knowledge of biological

interactions, by sparse data on noncommodity uses

and outputs, by model limitations for addressing

spatial relationships, and by inadequate analyses of

the efficiency of the management prescriptions used.

Finally, investment efficiency may require that

future investments be tied to current expenditures,

but Congress is reluctant to commit to expenditures

by future Congresses.

criteria generally, and FORPLAN in particular, to

determine the management balance for the national

forests, Congress and the public have rejected

efficiency as the standard for determining management direction. Furthermore, the beneficiaries of

many management activities pay less than the full

cost of producing the benefits, and some pay little or

nothing. The Forest Service has implicitly recognized these limitations in selecting forest plans that

do not maximize present net value. Instead, the

balance among uses, outputs, and protection can
158 ● Forest Service Planning: Accommodating Uses, Producing Outputs, and Sustaining Ecosystems

only be determined through public involvement-as

the Forest Service and the public discuss their needs,

concerns, and values and consider the possibilities of

achieving them through national forest management

(See ch. 5.)

The Impacts of Management

The impacts of national forest management on

communities are typically addressed in terms of

community stability. Congress has long expressed

concerns about community impacts, but the legislative direction to consider community stability in

forest planning is ambiguous. Nonetheless, forest

planning is to address local concerns, and locals are

often concerned about the impacts of management

on their communities.

The Forest Service generally uses an input-output

model—IMPLAN--to identify the economic impacts of management alternatives. IMPLAN estimates the employment and income by industry

sector for multicounty areas around each national

forest. However, this approach can mask impacts on

specific communities, because different resourcerelated firms may exist in separate communities

within a county. Furthermore, the wood products

industry is the only resource-dependent industry

identified as a separate sector in Commerce Department data; although the Forest Service is working to

improve IMPLAN, modifying the data to separate

recreation, livestock, and other resource industries is

an expensive and time-consuming task. Finally, the

imprecise definitions of community and of stability

limit the agency’s ability to fully display the impacts

of national forest management.

Traditionally, community stability has been equated

with sustained yield, particularly of timber, but no

evidence exists to show that sustained yield or

timber management can promote community stability. Furthermore, the Forest Service has no ability to

influence demand factors, which are important to

stable industry production, and it is questionable

whether the Forest Service alone bears responsibility for timber industry stability. Nonetheless, abrupt

changes in Forest Service timber sales can be

disruptive. Thus, the Forest Service has defined its

responsibility to communities as attempting to avoid

causing radical or abrupt shifts in local social and

economic patterns.

An additional significant impact of national forest

management is the potential effects on county

budgets. The Forest Service returns 25 percent of its

gross receipts to the States for use on the roads and

schools in the counties where the national forests are

located. In most years, more than 90 percent of

Forest Service receipts result from timber harvesting. Thus, to meet budget needs, counties often

support continued or expanded timber harvesting.

This is also a problem, because timber receipts can

fluctuate by 50 percent or more from year to year.

Counties need to be fairly and consistently compensated for the tax exempt status of the national forests

(and other Federal lands), but the current system

might not approximate tax compensation.

Planning and Budgeting

The budget may be the most important economic

concern in forest planning and in plan implementation, but the current budget system has serious

defects. Various national forests used different

budget assumptions in preparing their plans, some

constraining the budget to realistic alternatives and

others allowing any budget level. Because of this,

current forest plan budgets cannot be simply aggregated into an annual budget proposal for the

National Forest System. Unconstrained budget assumptions are useful for examining a full range of

opportunities, but realistic budgets are necessary for

displaying priorities and likely management activities to Congress and the public. Although difficult to

achieve, both types of budget assumptions should be

considered in planning.

Another problem is that the current budget system

subverts the integrated resource management required by NFMA. More than 50 functional line items

appear in the annual budget, with the funding and

output targets modified by the Forest Service

Washington Office, the Secretary of Agriculture, the

Office of Management and Budget, and the House

and Senate Committees on Appropriations. The

resulting appropriations bear little resemblance to

the integrated management presented in the forest

plans. In the field, the allocated funds and targets are

retranslated back into integrated projects, but the

allocations may not match the plans very closely.

This process leads to inaccurate reporting of costs

and accomplishments. Despite direction to report

expenditures accurately, they have often been reported as they were planned, without assurance that

actual expenditures match the plan. Furthermore,

while hard, measurable outputs are reported for
Chapter 8--Economics in National Forest Planning ● 159

commodity resources, the measures used for other

resources allow for substantial imprecision in reporting. (See ch. 6.) The Forest Service has proposed

“end-results budgeting’ to eliminate these problems, and the General Accounting Office has found

the test to accurately report expenditures. However,

measures that relate management efforts to changes

in resource quality and quantity are needed before

end-results budgeting can take into account all

resources.

Finally, permanent appropriations account for

nearly a third of the Forest Service budget annually.

Most of these special accounts and trust funds are

related to the timber program, deriving money from

timber sales and/or providing money for timber

management activities. Each national forest has

substantial discretion to determine the amount of

money available in several of these accounts, and in

one, the K-V Fund, the money can be used for any

management activity in a timber sale area. However,

the BLM operates without permanent appropriations

in western Oregon, suggesting that they may not be

necessary. No evidence has shown that permanent

appropriations are efficient, and there has been

virtually no congressional oversight or control over

these discretionary funds. Nonetheless, these permanent appropriations clearly can influence national

forest management, because managers have the

opportunity to increase their own budgets by increasing timber sales.
Chapter 9

Organizational Factors in

Forest Planning
. . - - - -- - - . . . . . .

Contents

Page

Professionalism and Diversity in the Forest Service . * . . * . . . . . . . * . * . . * * * * * . . . . * . ****....*

Professionalism ... ... ... ... ... ... ... ... ... ..*. .*** .*** .*. .**. *c C*** *e+

. *.*e***S***oe

Diversity 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

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Table Page

9-1. Forest Service Interdisciplinary Team Members . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 169
Chapter 9

Organizational Factors in Forest Planning

In some respects, the Forest Service appears to be

under siege even by some of its own employees. The

plans and the planning system are being attacked,

and the agency is accused of damaging the resources

and ecosystems it is mandated to protect. One

common allegation is that the agency’s problems

result from the dominance of professional foresters.

Others assert that the problems arise from the

unbalanced reward system for agency managers.

This chapter examines these allegations, and concludes by assessing the impacts of organizational

factors on forest planning.

PROFESSIONALISM AN D

DIVERSITY IN TH E

FOREST SERVIC E

This section explores the strengths and limitations

of the agency’s forestry-oriented professionalism,

examines diversity and the use of interdisciplinary

teams, and concludes by assessing organizational

and employee values.

Professionalism

Foresters

Foresters have dominated the ranks of the Forest

Service from the very beginning. Bernard Fernow,

Gifford Pinchot, and others emphasized the importance of professional forestry training for those who

manage forested lands, and focused on hiring

foresters for the agency (240). Today, professional

foresters are less dominant than in the past, but

foresters still account for more than 50 percent of

professionals and for more than 75 percent of the

technicians employed by the Forest Service (284).

Foresters, as any professional group, are bound

together by a common educational core and professional identity. The professional foresters organization—the Society of American Foresters (SAF)--

contributes to this cohesive identity by providing the

focus for professional activities and by accrediting

forestry school curricula. This assures that forestry

graduates are schooled to meet the needs of the

Forest Service and the forest industry, the major

employers of foresters. An interlocking network of

agency-university-industry establishes a successful

paradigm of scientific forest resource management

(316, 330). This paradigm emphasizes resource use

and has implications for the direction of forest

planning.

Emphasis on Use—The extent to which foresters

do and should emphasize timber production has

been debated for more than 50 years (31). SAF

Executive William Banzhaf (12) recently noted the

current SAF president and vice president reflect the

diversity among foresters in differing over “the

level of emphasis we as professional foresters should

give the production of wood for commodity uses.’

Wood production is an important part of national

forest management and of professional forestry.

Timber management has traditionally been at the

core of a forester’s training.

In the United States, foresters were initially

educated to be custodial managers with heavy

emphasis on timber production, an educational

philosophy 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 the

forest, based on the fear of a wood famine, interwoven with a puritan ethic that utilitarian or commodity uses are always more important than any

amenity values (29).

Foresters are the only professionals who have the

education and experience to manage forests for

wood production-they are the only ones who can

be the timber specialists (53). Thus, foresters must

be concerned with timber production.

This is not to suggest that foresters are all ‘timber

beasts,” with no interests other than maximizing

wood production. The forestry profession has long

endorsed the concept of multiple-use management,

and foresters in the Forest Service have recognized

multiple uses of forest lands since the Gifford

Pinchot era(131, 330). Wood production is only one

of the many forest uses, albeit an important one, but

managing trees is critical to many forest values, such

as aesthetics, water flows, and wildlife habitat.

Furthermore, forestry education exposes foresters to

–163–
164 . Forest Service Planning: Accommodating Uses, Producing Outputs, and Sustaining Ecosystems

all the various forest resources, and many foresters

have additional training in other resource specialties.

Nonetheless, foresters typically emphasize use of

the resources. The SAF Code of Ethics, for example,

focuses on forestry as practices, rather than on

forests as natural systems, and on management of

forest resources, rather than of forests (209):

. . . foresters’ traditional view of themselves [is] as

managing resource things (i.e., objects like trees or

game animals), rather than managing these resources

as objects of changing social values (including

non-consumptive and symbolic values) (129).

Some of the emphasis on uses comes from the

Gifford Pinchot tradition of unbiased, professional

management of the public’s lands. Prices (or other

measures of use value) are quantifiable, objective,

and unbiased indicators of public preferences, and

foresters prefer ‘‘neutral’ economics for assessing

social value over direct, emotional, face-to-face,

unquantifiable expressions of social value at public

hearings and political demonstrations (128). However, economics has developed better techniques for

valuing unpriced or subsidized uses and outputs than

for valuing nonuse benefits of forests. (See box 8-A,

p. 145.) Thus, foresters (and economists) unintentionally emphasize use of forest resources over other

forest values.

Implications for Forest Planning—The emphasis on forest uses has merit in national forest

planning. People care about the forests, and whether

and where to cut trees are central to much of the

debate over forest management. Thus, in some

respects, foresters’ emphasis on uses addresses

public interests and concerns. However, some forestry educators believe that foresters’ commitment

to the public interest has diminished:

A strong commitment to . . . the public good was

central to the forestry profession in this country

during the first half of this century. More recently,

however, this commitment appears to have declined

both within the profession and in the eyes of those

outside it (71).

Why do some believe that foresters’ commitment

to the public good has declined? Some foresters have

asserted that society has changed, and the profession

is 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 for

forest practices but the values most of the public uses

to judge them . . . Current logging is heavily

unbalanced toward just one system [clearcutting] . . .

William Ticknor of Mead Corp. (249) similarly

observed:

. . . the public is saying, “Even, when I understand

what you are doing, I still don’t like it.".

There is no debating matters of taste. You can’t

persuade a person to like broccoli, Penn tennis balls

or clearcutting. Or, preferring seedlings to mature

trees.

Others have noted that America is becoming more

urban and our urban society views nature more

romantically (26, 106). Urbanization has broken

many of the direct ties with utilization of nature, and

thus has led to the more romantic, less utilitarian

view of nature. Furthermore, this is not a social

change that can be corrected by ‘‘educating the

public. They know what they like, and are unlikely

to accept traditional justifications for standard forestry practices that have undesirable effects on the

nonuse values of the forests. This implies the need

to do things differently. Again, Scott Wallinger

(310) observed that:

. . . we [foresters and the timber industry] must adjust

to changes in public and landowner values and

attitudes, not just defend traditional ways.

And William Ticknor (249) added:

. . . I think we [foresters] will find it useful to put

aside the ‘‘we-they” mentality as we approach our

task, and acknowledge that we, as a society, want to

approach forest resource management differently in

the future than we have in the past.

. . . it is inevitable that forest practices, as we know

them today, are going to change.

Other Professionals

The Forest Service may still be dominated by

foresters, but the agency has always used other

professionals as well, and these are becoming a more

significant part of the agency’s personnel structure.

The Forest Service has traditionally employed

numerous engineers, with range conservationists,

soil scientists, hydrologists, economists, and other

specialists. Engineers are still important, accounting

for more than 10 percent of the professional

workforce and nearly 20 percent of the technicians

(284). Forest Service engineers are relatively similar

to 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 emphasis

on cost efficiency than do foresters (33).

In addition, over the past 20 years, the Forest

Service has added or expanded to include other

professionals, largely in response to the National

Environmental Policy Act (NEPA), the National

Forest Management Act (NFMA), and various other

laws governing the management and/or protection of

the national forests (l). Wildlife and fisheries

biologists have become the second largest professional group within the Forest Service, accounting

for nearly 15 percent of the professional staff (286),

but the agency also has landscape architects, archaeologists and anthropologists, and various other

professionals.

The agency has developed a strong cadre of

professionals in each of [the important resource]

areas (146).

Biologists have become a significant professional

subculture within the agency, ranking with engineers in numbers (33, 132, 133). While biologists

have much in common with foresters, they also

differ in several ways. Education in biology, not

surprisingly, focuses on biological and ecological

processes. In contrast to forestry, biology has not had

an industry to employ its graduates, and does not

have the lengthy historical focus on land management. Thus, biologists in the Forest Service typically

have a more biocentric, less utilitarian view of forest

resources than foresters have (33).

Other specialists within the Forest Service have

their own educational emphases, Landscape architects, for example, emphasize visual values, while

archaeologists and anthropologists are more likely

to be concerned with cultural values. However,

regardless of their training, most of these various

specialists share with foresters, engineers, and biologists a sense of professionalism, and undergo

rigorous education and training in their specialty.

Benefits of Professionalism

Perhaps the greatest benefit of Forest Service

professionalism has been the agency’s long history

of success. For more than half a century, the Forest

Service was viewed as a premier Federal agency,

being a relatively strong and independent entity in

managing resources for the public good. Shortly

after the passage of the Multiple-Use SustainedYield Act in 1960, one observer wrote that:

. . . the Forest Service has an esprit de corps and a

professional dedication unmatched in federal service

which should not be damaged. The present fine

condition of the national forests is a monument to the

devotion and ability of the Forest Service and this is

an important factor in any decision about the

appropriate scope of professional responsibility.

Others have noted the traditional view of district

rangers as local heroes (130) and the Forest Service

as a hero-agency (128). Few would argue that the

Forest Service had a long tradition of management

with relatively little public challenge to its authority

or direction, at least until the 1960s.

The Forest Service’s professionalism and history

of success (as measured by the lack of major public

challenge to management direction or authority)

have contributed to the agency’s unusual esprit de

corps. However, it may stem primarily from the

homogeneity and shared perceptions of the foresters

who have dominated the agency (50). Regardless of

the source, Forest Service employees have had a

consistent sense of mission matched by few Federal

agencies.

Preserving this strong sense of mission is the key

to maintaining the historic esprit de corps of the

Forest Service. Some employees are concerned,

however, that the management direction for the

national forests is not consistent with the current

motto “Caring for the Land and Serving People. ”

Forest supervisors have been particularly outspoken

in recent years about actions they perceive to be

inconsistent with the agency’s mission (90, 91).

Drawbacks of Professionalism

While professionalism has contributed to the long

history of Forest Service success and esprit de corps,

it also has drawbacks. The scientific conservation

paradigm (see below) limits the ways in which

professionals interact with the public, and public

trust in professionals has declined. These criticisms

have been directed principally at foresters, largely

because of their historic dominance of the Forest

Service, but apply to all of the professionals

employed by the agency.

The Scientific Conservation Paradigm—The

scientific conservation paradigm essentially presents conservation as primarily a scientific effort,

with a focus on correct technical practices and

procedures. This view was behind conservation

efforts of the mid-1800s, and persists largely
166 ● Forest Service Planning: Accommodating Uses, Producing Outputs, and Sustaining Ecosystems

through the education of foresters, biologists, and

other professionals in scientific and technical matters (330). Foresters are traditionally taught to be

objective, scientific managers (131), and ‘‘forestry

education emphasizes specialization, skill in quantification, and rational problem-solving approaches”

(315). Furthermore, the sciences (in contrast to

philosophy) typically eradicate disproven theories

from their texts, leading students to view their

education as the correct way of doing things (159).

This emphasis on technical matters creates numerous problems for the Forest Service in dealing

with the public. The agency has been accused of

‘‘groupthink,” whereby cohesive groups (e.g., foresters) view problems and potential solutions similarly (130), leading to insular and inflexible approaches (50). Such cohesiveness limits the individual’s ability to explore new solutions and opportunities (161).

The technical emphasis also contributes to public

perceptions of arrogance and aloofness (130). Foresters and other resource professionals are notoriously weak at interpersonal relationships: “many

professionals are reluctant to interact with ‘nonexperts, ’ those who are not members of their professional subculture’ (315). “Groupthink” among

professionals often results in unconscious or indirect

censorship of contrary or disquieting information

(130); “listening [to the public] seems to occur

without hearing’ the message (159).

Finally, the technical emphasis leads professionals to believe that they know the correct way of

doing things. This belief has been described in terms

of the traditional professional-client relationship,

with the client simply accepting the professional’s

decisions:

In the traditional professional-client relationship,

the professional’s expertise is wrapped in mystique,

and the client accepts the professional’s authority

and agrees not to challenge his judgment or demand

explanation (316).

The public is considered to be uninformed, and the

professionals are “ ‘uniquely qualified’ to make

natural resource decisions’ (159). Foresters and

engineers have been most likely to object to agency

decisions when they felt that politics or the public

was interfering in sound management (33). Furthermore, physical and biological scientists are more

likely to discount the public’s knowledge than are

social scientists (economists, sociologists, etc.) (237).

Foresters typically accept scientific answers, and

reject emotional ones:

The argument is that in our [foresters’] special

need to achieve scientific validation of everything,

we have invalidated most everything that we find

science cannot examine. In the process of secondrating all that is not “scientific’ we have devalued

romantic, emotional, and intuitive insights. We have

trained hard to distrust those voices in ourselves and

others, lest they prove to be unsound (106).

This is not to suggest that technical information is

not important in forest planning. Indeed, technical

analysis is essential, but it is not enough.

Technical competence is a necessary but not a

sufficient condition for success in public forest

resource management (316).

In its recent critique of land management planning,

the Forest Service noted that it began the process

expecting to find the ‘‘right’ scientific answer for

how to manage the national forests (276); the

critique concluded, however, that many technically

correct answers exist for land management, and that

the public should be involved in determiningg which

of the technically correct answers is most desirable

socially.

The problem is not so much public ignorance of

resource management as professional ignorance of

the public (159).

William Ticknor (249) described the situation this

way:

Traditional forest science is the essence of a

left-brain endeavor. . . analytical, quantitative, logical, linear. Most of us who are practitioners are so

because that’s the way we were trained, and because

we enjoy and excel at left-brain pursuits.

But the solution to our problem, I propose, is to

move toward a more intuitive, multidimensional

approach which places a high priority on blending

the not inconsiderable scenic, aesthetic and spiritual

aspects of forestry with the biological and business

aspects.

Decline in Trust of Professionals-Several authors have noted that the decline in public trust of

foresters is not unique. Society appears to have less

trust for all professionals (1 12, 158), including those

in other government agencies, such as the National

Park Service (316), and outside the government. The

list includes lawyers, engineers (121, 315), and
Chapter 9--Organizational Factors in Forest Planning ● 167

doctors, as indicated by the rising cost of, and need

for, medical malpractice insurance.

Some have suggested that part of the problem is

the lack of public consensus about the proper

management of the national forests (158). One

observer wrote:

We [foresters] do have a difference of opinion

within our ranks (which mirrors society) about how

lands should be managed . . . Our image will never

return to its previously untarnished sheen because

our increasingly complex and strident society cannot

form a single vision of what it seeks. Probably the

best we can hope for is an uneasy consensus (95).

Thus, it seems that the public is simply less willing

to accept the knowledge and expertise of professionals 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, male

organization (more than 50 percent of all employees

and nearly 75 percent of professionals are white

males), the number of women and of minorities

doubled between 1976 and 1989 while total employment climbed by only 20 percent (284). Furthermore, as noted above, the dominance of foresters is

declining as the agency adds biologists, landscape

architects, archaeologists, anthropologists, and other

specialists.

The change is not problem-free. The Forest

Service has been successfully sued in California

(Region 5) for its slow development and promotion

of female employees. The addition of numerous

planners and computer specialists for using

FORPLAN and preparing the forest plans has caused

culture shock—both to the traditional employees

and to the new recruits (146). Organizations have a

strong, innate tendency to exclude ‘‘outsiders’ the

Forest Service’s history of success, for example, has

led to ‘‘resistance to incorporating the nonutilitarian,

amenity values of a post-industrial urban nation . . .

and a manifest reluctance to share power with the

public and with other professionals” (130).

We [foresters] are fond of saying our diversity is

our greatest strength, but right now it really isn’t. The

way many of us are going about our business is

bringing us to denial and intolerance instead. If

diversity 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 and

gender differences found that, a female forester is

much more like a male forester than a male biologist

is like a male forester. “[M]ost of the job frustration

and prejudice women and men experienced were

related to their [wildlife and fish biology] profession

confronting traditional timber-range chauvinism’

(132). Gender diversity is important for many

reasons, but educational diversity is more important

in terms of diversifying ideas and opinions.

Benefits of Diversity-Increased diversity within

the Forest Service can yield several benefits in forest

planning and public involvement. A diverse

workforce brings a broader array of ideas, leading to

greater creativity and flexibility for the organization.

“Professional monoculture” resist change (132),

and often unconsciously or indirectly censor information that contradicts insider views (130). Five out

of six Forest Service interdisciplinary (ID) team

members felt that “ID teams foster a holistic

approach to problem-solving” (94). Furthermore,

“creativity in environmental problem solving is a

group activity that involves inputs from many

different fields” (94).

Workforce diversity also can improve public

involvement. Various segments of the public prefer

different kinds of involvement in activities and

decisions (159, 231). A diversity of professions,

ages, and genders provides more avenues for various

groups to be heard.

Diverse disciplinary backgrounds and generational differences create centrifugal forces that

provide access to sympathetic decisionmakers by a

broad range of groups (237).

Finally, diversity also provides a broader spectrum of values among agency employees (133). One

reason for using interdisciplinary teams is ‘‘to

overcome the narrowness of a single professional

focus” (94). Foresters tend to focus on utilitarian

values, and downplay the spiritual, symbolic values

of the forest (128, 209). Biologists, in contrast, place

greater value on biological processes (33), and these

ecological values are more akin to the intrinsic

values our substantially urban society holds for

forests (194, 209). By combining the variety of

values of a diverse workforce in its planning and

management, the Forest Service could generate

broader support for its activities and plans.
I@ ● Forest Service planning: Accommodating Uses, Producing Outputs, and Sustaining Ecosystems

Costs Costs of Diversity--Increasing workforce diversity also imposes costs on the Forest Service. One

major cost is increasing internal conflict. To the

extent that the conflicts are professional differences

about technical matters, such conflicts can be

beneficial, fostering creativity and flexibility. However, many of the differences occur because nontraditional employees are challenging the traditional

assumptions and operating styles, and thus become

“change agents” within the agency (130). Challenges to “standard operating procedures” are often

viewed as disloyalty to the agency, and can damage

career prospects (104, 132). Sometimes the differences among staff devolve into personal conflicts

(94), and can be very disruptive.

It is also difficult to build a team from a collection

of diverse individuals. Time is required to overcome

distrust of other professions and to abandon the

resource advocacy roles many employees must

employ during budget negotiations (94). ID teams

still often operate as a collection of advocates rather

than as a team:

Consensus is not the norm on most interdisciplinary teams; rather the relationship among most team

members is adversarial and, in some cases, antagonistic (13).

Frequent changes in interdisciplinary team membership complicates the task of fostering teamwork, as

employees are hired, transfer to other positions or

locations, or leave the agency. In addition, some ID

team members have only part-time team duty and

many nonteam duties (94). Thus, building an effective interdisciplinary team is a difficult and challenging task.

Strategic planning can overcome some of the

problems of workforce diversity. If a strategic plan

establishes a sense of mission that is consistent with

the values of the employees, and of the public, all of

the diverse elements of the agency can be brought

together to implement the plan. As noted above, a

strong sense of mission can rekindle the esprit de

corps that has traditionally been one of the Forest

Service’s strengths. However, this entails more

tolerance of diverse opinions and of challenges to

traditional practices. Moreover, achieving a unity of

mission and sense of teamwork is a time-consuming

process.

Use of Interdisciplinary Teams

The use of interdisciplinary teams in national

forest planning is mandated by NFMA and NEPA.

However, the functional organizational structure has

inhibited integrated forest planning. As noted in ch.

7, FORPLAN has in some ways forced the various

specialists to learn to talk a common language (123,

278), but it also has contributed to advocacy by the

various specialists (13). Furthermore, when debates

become “use versus nonuse” (rather than how to

achieve all relevant values), they can polarize both

internal and external groups (160). FORPLAN

creates other barriers for many employees who are

not on the planning team, and thus can separate

planners from managers and other employees (23).

Nonetheless, to the extent that teamwork can be

created, ID teams can lead to more effective,

coordinated planning (94).

Most ID teams used in national forest planning

include 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 in

their area of specialty (94). However, some specialties are represented by employees trained in other

areas. For example, foresters dominate the recreation, hydrology, and economic specialties (94). This

does not necessarily mean that these people are

unqualified to perform the necessary tasks, since

many foresters have additional training in other

disciplines. Nonetheless, to the extent that foresters

are used in an assortment of specialty roles: 1) the

benefits of educational diversity will not be achieved,

and 2) foresters may lose the special characteristics

that make them a distinct profession. Some forestry

educators have noted this as a possible problem:

. . . as foresters fill evermore varied assignments, the

term 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 teams

except in planning, and ID team outside planning use

has been rather limited. Several forests, such as the

Allegheny in Pennsylvania and the Lolo in Montana,

have apparently reorganized away from the traditional resource functional approach. However, the

Forest Service is still generally organized by resource function, especially at the regional and

national offices (276). Furthermore, despite the

importance 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 Degree

Specialty team use Degree in specialty forestry in other

(percent) (percent) (percent) (percent)

Wildlife . . . . . . . . . . . . . . . . . . . . . . . . . . . 91%

Timber . . . . . . . . . . . . . . . . . . . . . . . . . . . 89

Recreation . . . . . . . . . . . . . . . . . . . . . . . . 76

Team leader . . . . . . . . . . . . . . . . . . . . . . 75

Engineering . . . . . . . . . . . . . . . . . . . . . . . 74

Visual quality . . . . . . . . . . . . . . . . . . . . . 73

Hydrology . . . . . . . . . . . . . . . . . . . . . . . . . 69

Planning . . . . . . . . . . . . . . . . . . . . . . . . . . 64

Soils . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 64

Program analysis . . . . . . . . . . . . . . . . . . 59

Economics . . . . . . . . . . . . . . . . . . . . . . . . 58

Range . . . . . . . . . . . . . . . . . . . . . . . . . . . . 54

Fire . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 52

Public involvement . . . . . . . . . . . . . . . . . 47

Lands . . . . . . . . . . . . . . . . . . . . . . . . . . . 41

Archeology . . . . . . . . . . . . . . . . . . . . . . . . 38

Fisheries . . . . . . . . . . . . . . . . . . . . . . . . . 30

Writing . . . . . . . . . . . . . . . . . . . . . . . . . . . 27

Sociology . . . . . . . . . . . . . . . . . . . . . . . . . 23

Geology . . . . . . . . . . . . . . . . . . . . . . . . . 13

80%

95

40a

2

90

97

46

0

78

4

24

47

0

51

0

8 9

b

80

21

41

82

(biology)

(forestry)

(recreation)

(planning)

(engineering)

(landscape architecture)

(hydrology)

(soil science)

(computer science)

(economics)

(range conservation)

(social science)

(archeology)

(biology)

(English)

(sociology)

(geology)

4Y0

95

52

64

2

0

46

71

100

56

40

31

82

41

88

0

0

29

0

0

6%

5

8

34

8

3

8

29

12 &

40

36

22

18

8

12

11

20

50

59

-. .- -., 18

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;’ Environmental

Management13 (5):583-592, 1989.

success is still symbolized by the “heroic district

ranger”:

Although agency guidelines .. . are stressing the

importance of teams working together in cooperation with other organizations and the public, the

traditional image of the strong, heroic individual still

has considerable symbolic potency in the Forest

Service (131).

The resource functional approach to national

forest management is particularly a problem for

budgeting. As discussed in chapter 8, the forests

develop budget requests based on their interdisciplinary forest management plans, but these integrated

requests are translated into resource functions, to

meet the current requirements of the administration

and the House and Senate Committees on Appropriations (217). Actual appropriations are then allocated

to the forests, with substantial discretion vested in

the regional resource staffs (217). Resource specialists at the national forest level must compete for

funds with comparable specialists from other forests

and with other specialists on their own forest. Thus,

the current budget process inhibits an interdisciplinary or integrated approach to project planning and

implementation.

Organizational and Employee Values

Successful organizations in American business

have distinctive corporate cultures that contribute to

their success (195). Those corporate cultures typically provide both the stability needed by organizations and their employees and the ability to evolve

as the needs of customers (and society) change.

Stability is provided by the formal structure-the

laws, rules, and regulations governing the organization—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 Service to be among the best of Federal agencies (109,

128, 250). The agency certainly has a distinct culture

that has provided stable direction for the national

forests for many decades. Evolution in response to

social changes is more problematic. Some have

argued that the Forest Service has not responded to

changes in social values (161, 310, 320). However,

others suggest that the Forest Service has been more

effective than other agencies at evolving to meet the

requirements and intent of NEPA ( 1 ), and has at least

recognized the broad mandate for national forest

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

To their credit, the principal public land agencies,

the Forest Service and the Bureau of Land Management, have been seeking larger roles for wildlife on

the millions of acres in their charge (197).

Recent research has examined employee perceptions of agency and personal values, and found

substantial differences. The following sections describe apparent organizational values and employee

values, and explore the reasons for the differences

that have been found.

Organizational Values

Many Forest Service critics have alleged that the

agency is biased toward timber production (66, 104,

187). A survey of employees found that employees

also believe that the agency values timber more

highly than other resources; other resources are

valued equally among themselves (133, 250). The

belief in timber’s primacy is also reflected in the

recent letters from forest supervisors to the Chief of

the Forest Service asserting that current programs

are not consistent with proper land stewardship (90,

91). This belief permeated the agency, from new

employees to forest supervisors, and even to top

management (regional foresters and the Chiefs

office) (133).

Others who have examined the Forest Service

conclude that agency actions reflect an inherent bias

not toward timber, but toward maximizing its budget

(124, 187). O’Toole (187) in particular has suggested that the agency only appears to emphasize

timber production because of the numerous special

budget accounts associated with timber harvesting.

(See ch. 8 for a discussion of these accounts.)

Another study suggests that the reliance on standard

procedures and the civil service protections from

political interference account for the agency’s efforts to maximize its budget (213). Despite their

logic and some evidence to support these arguments,

other evidence suggests that the Forest Service has

not taken full advantage of the opportunities to

exploit its special budget accounts (298). Thus, the

budget maximization hypothesis is insufficient to

account for Forest Service values and actions.

Studies have shown that Forest Service employees believe the agency primarily values productivity

and team spirit (132, 133). Productivity includes

meeting targets, working hard, and being competent,

while team spirit includes loyalty, teamwork, promoting the Forest Service image, and getting along

with your peers (133). Team spirit is clearly

important to the Forest Service and its traditional

esprit de corps. Displaying behaviors consistent

with agency values is considered pivotal for success

in the agency (131). This belief, along with the

perception that the agency values timber over other

resources, is widespread among the employees, with

little difference by gender, professional background,

or level of experience and responsibility (132, 133).

Such views are not inappropriate, but can have

unintended consequences. One potential problem is

that, although the agency’s “New Perspectives” is

an attempt to encourage internal change, challenges

to traditional practices and procedures are often

perceived as disloyalty (130). This is more likely to

be a problem for nontraditional employees, such as

biologists and landscape architects, and could hinder

the agency’s ability to adapt to changing social

values. Another potential problem is the message to

new employees-’ ‘don ‘t make waves’ and ‘‘go

along to get along” (104). While such messages are

important to team spirit, they can inhibit employees

from speaking out and thus inhibit challenges to

traditional practices and procedures.

Employee Values

In many respects, employee personal values differ

from the organizational values of the agency. Forest

supervisors have noted that their values and those of

their employees have been changing (90). In contrast

to the agency’s apparent emphasis on timber resources, employees report that they value recreation

higher than other uses, followed by wildlife and then

water (133). Again, this is true for employees at all

levels in the agency, even top management (regional

foresters and the Chief’s office). These values,

moreover, matched employee perceptions of the

public’s values. Thus, employees believe that the

agency values timber relatively more than either

they or the public does.

Employees also believe that the agency should

reward additional behaviors. Professional competence, hard work, and teamwork are and should be

rewarded, but employees believe that concern for

healthy ecosystems, for the long-run future, and for

the welfare of one’s peers should also be rewarded

(133). Again, employees at all levels shared similar

beliefs about what the Forest Service should reward.
.

.—..——

Chapter 9--Organizational Factors in Forest Planning ● 171

Why Are There Differences?

One might hypothesize that differences between

organizational and employee values exist because

new employees differ from experienced employees.

Differences do exist-new employees are older at

the beginning of their Forest Service careers, they

are more likely to hold advanced degrees, and more

are biologists and fewer are foresters (133). However, as noted above, these differences did not lead

to differences in opinions about agency and personal

values. The letters from the forest supervisors to the

Chief also suggest that the managers’ views are

relatively consistent with those of their employees

(90, 91). In fact, some of the long-time employees

have been among the leaders in supporting Forest

Service changes:

. . . many of these senior people have become

adjusted to the challenges and promise of the

post-NEPA era, and have supported and authored

innovative approaches . . . (130)

Thus, it seems that increasing diversity is not the

source of the differences between agency values and

employee values.

Some differences probably occur because of the

tradition and inertia common to large organizations.

The Forest Service certainly has along and respected

tradition (13 1), and it is difficult to change comfortable and successful modes of operation (161). The

Forest Service has also institutionalized its traditional practices through common training, promotion from within, and regular transfers (250). Some

argue that historic patterns persist because of procedural standards and civil service protections for

government employees (213). Finally, the idea that

change is necessary also implies that traditional

practices represent the wrong way to do things (1 1).

Despite the clear changes in social values, it is

difficult to distinguish the appropriateness of past

procedures for their era from the current relevance

(or irrelevance) of such procedures.

The various external pressures on the Forest

Service also limit the ability of the agency to alter

agency values. External constituencies-’ ’the welter of interdependent organizations surrounding the

organization in question’ (316)----impose some

rigidity tending to hold the Forest Service to the

status 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 values

and employee values can result from the reward

system. Perceptions of agency values may simply

reflect the reward system rather than the organization’s actual values. Many have suggested that

achieving timber targets is more strongly rewarded

than achieving other targets (66, 104). New employees, forest supervisors, regional foresters, and the

Chief’s office all “give the agency reward system a

low legitimacy rating” (133)--i.e., what the employees believe the agency rewards does not match

what they believe it should reward.

Employees gave overwhelming endorsement that

the vision statement values should be rewarded by

the USFS [U.S. Forest Service] . . . and there was

little disagreement between ranks, gender or professional identity. However, most survey respondents

believed the agency reward system did not adequately endorse and support these values (133).

PERFORMANCE AND REWARDS

Performance 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 success

requires that appropriate performance be rewarded

(195). Assessing performance is more difficult for a

government agency than for a business, because

government agencies rarely have simple, financial

measures of success. Nonetheless, individuals and

organizations respond to incentives (187), and thus

a system that rewards appropriate performance is

necessary.

As discussed above, Forest Service employees

believe that the current system does not consistently

reward behaviors that promote the Forest Service

motto of Caring for the Land and Serving People.

Forest supervisors have written to the Chief that we

just can’t continue to do more [more targets, more

initiatives, more customer service projects, more

conflict resolution] with less [money and people]”

(91). According to employee opinions, the agency

rewards production and team spirit (133). Thus, this

section explores the agency’s reward system, and

assesses the relationship between that system and

the planning system.

Production

Production is an important part of any organization’s performance. Employees have reported that

the agency rewards professional competence and
172 . Forest Service Planning: Accommodating Uses, Producing Outputs, and Sustaining Ecosystems

hard work, and, to an even greater extent target

achievement (133). This seems appropriate, since

successful efforts (meeting the goals) should be

rewarded more highly than unsuccessful efforts.

However, observers have suggested that timber

targets are more important than other targets to the

Forest Service (104); at least timber target achievement is assessed more diligently than other performance (217).

Obviously, employees are likely to expend more

effort to achieve objectives that are measured than

those that are not. Nonetheless, the lack of appropriate measures of performance is a surprisingly

common failing of unsuccessful businesses (195).

The entire purpose of the management-byobjectives system widely touted in the 1960s was to

identify measurable targets that employees and their

supervisors could agree on (220). One problem for

the Forest Service is the lack of appropriate performance measures for some of the objectives for national

forest management (100).

What Gets Measured, Gets Done

Meeting targets is clearly important to the Forest

Service, but what targets get measured? The answer

is not as simple as it may seem. The 1990 OTA

report on RPA planning (259) assessed the annual

Report of the Forest Service, and found it to be an

inadequate report on Forest Service performance.

Management activities for the national forests are

displayed, but activities are generally not related to

targets for national forest outputs or conditions. The

only output information contained in the Forest

Service’s annual report which shows the results of

management 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, directly

measurable outputs of commodity resource programs: board feet of timber, number of cows or sheep

grazed, mineral leasing permits issues (217).

Forest Service managers, not surprisingly, focus

their efforts on meeting such ‘‘hard targets.”

Whether or not a forest supervisor has met his or

her assigned target for timber sale volume is quickly

and unequivocally determined by direct, physical

measurement; whether recreation or wildlife targets

have been met is a matter of broad professional

judgment . . .

Forest Service field officials indicated that the

primary focus of performance evaluations continues

to be the attainment of the “hard targets” for timber

and, to some extent, range and minerals. On most of

the national forests, the district rangers in particular

indicated that their overwhelming management concern relating to their own performance evaluations

was to ‘‘get out the cut, ’ that is, meet the annual

timber sale volume targets assigned them (217).

The important timber targets are not those established in forest planning, but the targets set in budget

process. Congress typically sets targets only for

timber in the annual appropriations laws (217).

Furthermore, congressional timber targets have consistently exceeded the timber sale levels requested

by the Forest Service for the past decade (217)

although the timber funding and outputs in the

agency’s budget request have been below those

identified in the forest plans with unconstrained

budgets. Thus, meeting the annual timber targets is

clearly important to meeting congressional direction

for national forest management.

What Isn’t Measured, Is Important

In contrast to the hard targets for timber and other

commodity outputs, the measures for noncommodity resources are called ‘soft targets. ’ As noted

in chapter 6, consistent and comprehensive measures of nontimber outputs do not exist. Measures of

recreation use, for example, have been described as

“horseback estimates” (217). Wilderness management is reported in acres managed, which is a

function of congressional wilderness designations,

not of managerial performance (215). The ‘output’

of watershed management depends more on the size

of the watershed treated than on the efforts or the

results (217).

Equally important is the lack of measures of

resource and ecosystem conditions. Range, watershed, and wildlife habitat improvements are measured in acres, but results of these efforts are not

reported in terms of changes in conditions (100).

Even for timber, the Forest Service does not report

on changes in resource quality (215).

The Forest Service also does not assess production costs. (See also ch. 8.) Cost data reported

nationally are incomplete and inconsistent with

appropriations data (259). Unit costs are no longer

important to managers in annual budgeting, and

inaccuracies result in few sanctions (217). Further-
——..

.

Chapter 9-Organizational Factors in Forest Planning ● 173

more, costs are not related to outputs, even for the

hard targets, in any meaningful way (217, 254).

It is difficult, if not impossible, to hold Forest

Service managers accountable for all the relevant

management tasks when appropriate measures for

costs, outputs, and conditions are lacking. It is

admittedly difficult to develop measures for all the

tasks. However, without such measures, Forest

Service managers will continue to be evaluated on

achieving the hard targets for national forests. In

particular, managers cannot be rewarded for achieving and maintaining healthy ecosystems (as employees at all levels believe they should) unless the health

of ecosystems is measured, at least indirectly.

Team Spirit

Loyalty, teamwork, and other measures of team

spirit are even more difficult to assess. The Forest

Service has stressed the importance of teamwork,

but has done little to reward or encourage it (131).

Little research has been conducted on how to build

and maintain esprit de corps, probably because of the

difficulties in measuring and assessing it. Clearly,

team spirit is important, and has been a traditional

strength of the agency. Equally clearly, team spirit,

as measured by employee pride in the Forest

Service, has declined at all levels of the organization

over the past 20 years (133).

Team spirit will be more difficult to build and

maintain with the increasing professional, racial,

and gender diversity within the agency. Challenging

traditional practices is often construed as disloyalty

(130), but challenge is likely to be more common in

a more diverse agency. Challenge--if done within

proper and necessary limits-is an appropriate way

of assuring that the agency is responsive to its

mission and to the public. An open, strategic

planning process, wherein employees and the public

agree on management direction for the national

forests, can lead to a spirit of cooperation and

consistency.

Rewarding Plans and Planning

Forest plans are not just pretty documents to set on

a shelf and gather dust. The plans must be implemented—to guide management of the national

forests. Forest supervisors must ultimately be responsible for the forest plans and their implementation, and must make the time to ensure the plan is

right. “The manager should be willing to devote

considerable personal time to the process” (60) to

motivate the planning team and assure that the

results are feasible.

Plan Feasibility

Clearly, plans must be technically feasible. The

chosen alternative must be internally consistent—all

the outputs must be achievable and the ecosystems

protected. Foresters and other professionals are quite

good at examining technical feasibility; as described

above, the scientific conservation paradigm common to many physical and biological disciplines

emphasizes the technical aspects of management.

The plans must also be politically feasible, at the

local and national levels; technical competence is a

necessary but not sufficient condition for successful

national forest management (316). It has long been

recognized that public involvement is needed to

understand the social values of the forest (29). The

forest supervisors have reiterated the call for effective public involvement, arguing for increasing work

with “local, state and national key publics and

elected leaders’ (90). (See ch. 5.)

A major difficulty for forest planning is the lack

of public consensus on how and for what the national

forests should be managed ( 158). Foresters and other

professionals are typically not very good at face-toface, emotional confrontations about management

(129). Many of the planning ‘failures result because

resource professionals are working to change the

public’s mind about management practices rather

than developing alternatives to satisfy public goals’

(159). However, foresters have traditionally been

committed to serving the public interest (71). This

commitment to service must be strengthened and

molded to building a public consensus, because

consensus is crucial to building politically feasible

forest plans (158, 231).

Some have described the goal of the forest

planning process to be a “social contract” between

the agency and the public (130, 230). This view is

useful, but may not recognize the need for plans to

be politically feasible at the national level—i.e.,

consistent with the RPA Program, the annual

budget, and other national policy direction from

Congress and the administration. (See also ch. 10.)

Research indicates that national RPA direction has

had relatively little direct effect on the forest plans

(213). However, national direction on budgets and

on targets can subvert the direction established in the
174 ● Forest Service Planning: Accommodating Uses, Producing Outputs, and Sustaining Ecosystems

plans, as described above. Forest plans must be

consistent with likely national decisions about

budgets and targets and other policy guidance, if

they are to be implemented. This probably will

require modifying the planning and budgeting processes to impose some consistency in budget consideration, and to display how budget changes will

affect forest plan implementation. (See also ch. 8.)

Manager Responsibility

Another requirement for implementing the forest

plans is that the managers-forest supervisors,

district rangers, etc.—be accountable for performing

according to the plan. Plans are unlikely to be

implemented if managers are not held responsible in

performance reviews for both the technical and

political feasibility of the plans.

Technical feasibility can be assessed annually by

comparing actual outputs, changes in conditions,

and unit costs with those projected in the forest plan.

Some variability is certainly to be expected, and

unanticipated events, such as Hurricane Hugo, can

devastate a forest. Nonetheless, if the plan was done

correctly, it should give a reasonably accurate

projection of activities, costs, and results. Managers

and their planning teams should be evaluated, in

part, on the output condition and cost targets in their

plans.

The public also needs to examine the activities,

costs, and results of management annually. The

annual Report of the Forest Service was intended to

provide such information at the national level,

although it has not fulfilled this task (259). A

comparable annual report on the consequences of

implementing the forest plan could provide the

public with the relevant information, and many

forests are now preparing annual reports (137).

However, as discussed above and at greater length

under monitoring in chapter 6, the existing measures

of outputs and activities are inadequate to assess the

results of management activities on total outputs,

ecosystem conditions, and unit costs. The lack of

complete and relevant measures of national forest

production make it difficult to evaluate how managers perform in implementing the forest plan.

Political feasibility, at least at the local level, is

also important to implementing forest plans. One

simple and obvious measure is the number of

administrative appeals and lawsuits filed against a

plan. Agency critics have suggested that the apparent increase in litigation, despite increasing public

participation efforts, suggests that the agency is not

really responding to the public (159). However, one

should also recognize that the plans and the subsequent activities cannot be “bomb-proof,” because

forest plans are not comprehensive, site-specific

action plans (13). Forest management is often

contentious, and thus some appeals and litigation

should be expected. Furthermore, conflict, and even

litigation, are not necessarily bad, because they can

lead to improved understanding and agreement.

Nonetheless, managing conflict and reducing appeals and litigation is a relevant goal for Forest

Service managers, and the agency does reward

managers who deal with contentious issues at the

local level (217).

The number of appeals and lawsuits is one

measure of local conflict over management decisions: fewer appeals and lawsuits suggest better

conflict management. However, it is possible to

reduce appeals and lawsuits without resolving conflicts, by postponing controversial decisions to a

later date or to another forum. Managers could,

through such techniques, shift the controversies to

their successors or to other decisionmaking forums.

Thus, the number of appeals and lawsuits is an

incomplete measure of the political feasibility of a

forest plan. Additional measures of the effectiveness

of public involvement and manager responsiveness

need to be developed to assure that managers are

properly rewarded for preparing politically feasible

forest plans.

Difficulties in Accountability

As noted above, the lack of complete and accurate

measures to assess the technical and political

feasibility of forest plans is a problem. Another,

related problem is objectivity-it is difficult for

managers and planners to be impartial in monitoring

and evaluating the plans they have spent so much

time and effort preparing (50). Effective, unbiased

assessment of performance requires monitoring by

quasi-independent groups within the national forests, such as interdisciplinary teams that include

nonemployees (e.g., retirees and experts from various interests). However, purely external monitoring

and evaluation can reduce planners’ and managers’

commitment to developing effective, implementable

plans.

A more intractable problem relates to the frequency of transfers for agency employees. Habitual
Chapter 9-Organizational Factors in Forest Planning ● 175

transfers, including laterals, are important for employees to advance in the organization, but often

drain local expertise from a forest (64) and can be a

problem for dual-career families (132). Furthermore,

frequent transfers and the inability to quickly

demonstrate improved resource quality mean that

managers face relatively little risk of being held

responsible for failures to meet resource quality and

ecosystem health targets (215).

In the extreme case, transfers can make one

manager and planning team responsible for implementing a plan prepared by another manager and

team. Two steps can minimize this potential problem. First, the plan should identify all the relevant

information needed for implementation: the participants, their issues and concerns, the current outputs

and conditions and their trends, and the goals and

direction for managing the forest. Second, improved

communication and a sense of shared responsibility

is needed between employees and their predecessors. This would include informal talks as well as

formal communication, and possibly even joint

performance review.

SUMMARY AND CONCLUSIONS

Organizational factors, such as traditions and

incentives, affect the ability of an organization to

develop and implement strategic plans. Within the

Forest Service, the traditional dominance of foresters is changing as the agency’s workforce diversifies

and as foresters adapt to changes in American

society, but Forest Service tradition still exerts a

strong influence over national forest management.

The reward system for national forest management

also determines the effectiveness of strategic forest

planning under NFMA.

Forest Service Culture and Diversity

The Forest Service has long been dominated by

foresters, and foresters still account for at least half

of the agency’s professionals and at least threequarters of its technicians. Foresters, by training and

experience, typically emphasize the uses and outputs

of forests, and particularly, the management of trees.

However, the increasingly urban American society

holds a less utilitarian, less anthropocentric, more

romantic view of nature. Thus, society increasingly

values the nonuse benefits of forests, which are often

discounted by foresters.

The Forest Service also employs a variety of other

professionals. Traditional engineers and range conservationists hold values relatively similar to foresters, and thus have contributed to the agency’s

consistent internal philosophy. However, other professionals, such as biologists, landscape architects,

and archaeologists, are diversifying the educational

background of the agency’s workforce, Biologists

have become the second largest professional group

within the Forest Service (after foresters), and their

education typically emphasizes the biological and

ecological processes of forests, rather than the

utilitarian view of foresters. Thus, as more biologists

and other specialists are employed, the values and

orientation of the agency is broadened.

As a Federal agency, the Forest Service has long

been highly regarded for its professional approach to

its mission. The professionalism of Forest Service

employees has contributed to the agency’s historical

success and to the strong esprit de corps within the

workforce. However, professionalism also has its

costs. The professional training of foresters and

biologists emphasizes technical competence. While

technical competence is important to, and indeed

necessary for, management of the national forests, it

inhibits listening to the public. The public is

generally perceived as uninformed and overly emotional, while the professionals consider themselves

specially qualified to make rational resource management decisions. However, this view often leads

professionals to ignore or discount the public’s goals

for the national forests and public objections to some

common management practices.

The Forest Service workforce is becoming more

diverse, in racial and gender as well as educational

composition. Research suggests that educational

diversity is more important than racial or gender

diversity in terms of broadening the values and ideas

of the workforce. Such diversity is important because it leads to greater creativity and flexibility in

management, tends to open more channels of

communication to various interests, and broadens

the basis for management decisions. However,

diversity also creates internal conflict, because new

ideas often challenge traditional practices and can

seem to be disloyalty to the agency. It takes more

time and effort to build teamwork and trust among

groups with disparate backgrounds and values than

among groups with shared outlooks and experiences. A shared sense of mission can overcome

some of the difficulties, but many employees are
176 ● Forest Service Planning: Accommodating Uses, Producing Outputs, and Sustaining Ecosystems

concerned that the current motto--"Caring for the

Land and Serving People’’—is not really being

implemented and rewarded.

Diversity is important to developing and using

interdisciplinary teams as required by NEPA and

NFMA. The Forest Service uses ID teams in forest

planning, although in many cases the diversity of

specialists is less than that specified in the laws.

More importantly, however, the interdisciplinary

approach is not used widely other than in forest

planning; the Forest Service is still generally organized functionally, by resource specialty. This is

particularly a problem in budgeting, as integrated

management activities are translated into resource

functions; the subsequent appropriations may bear

little relationship to integrated management.

Finally, the apparent values of the organization

and the employees differ significantly. Regardless of

experience, level within the agency, or educational

background, employees believe that the agency

emphasizes timber above other resources, and primarily rewards outputs and team spirit. However,

employees’ personal values apparently emphasize

recreation, wildlife, and water, and match their

perception of the public’s values. Employees believe

that the agency should also reward healthy ecosystems, long-run concerns, and the welfare of their

peers. However, the agency’s traditions, normal

organizational inertia, pressures from various external groups, and the existing reward system all

impede change.

Performance and Rewards

As noted above, employees believe that the Forest

Service rewards production and team spirit. Production and productivity are appropriate standards for

evaluating employees, but the existing measures are

incomplete for assessing performance. ‘‘What gets

measured, gets done. Timber and other commodity

outputs are more easily and accurately measured,

and thus commodity output goals are commonly

known as “hard targets.” Other national forest

goals--noncommodity outputs, nonuse values, and

efficiency (unit costs)--are either poorly measured

for annual production (i.e., they are “soft targets”)

or are not measured at all. Thus, employee performance evaluations emphasize achieving the hard

targets.

Spirit is far more difficult to measure, and thus to

assess, than is production. One problem for establishing and maintaining esprit de corps in a diverse

workforce is that challenges to tradition are often

perceived as disloyalty to the agency. Strategic

forest planning can overcome such perceptions, if

the established direction and the subsequent management are widely accepted by the employees (and

the public).

Successful implementation of forest plans must

also be rewarded. To be implemented, the plans must

be technically feasible, something the various professionals employed by the Forest Service are

trained to assess. However, the plans must also be

politically feasible. This means building a local

public consensus on the appropriate management

direction and practices for the forest plan, an

admittedly difficult but essential task. The resulting

“social contract” must also be politically feasible

from a national perspective, fitting with the nationwide goals for resource management and for Federal

budget priorities and limitations.

Accountability is the key to forest plan implementation. The limited number of performance measures

make it difficult to hold managers responsible for

achieving all the management goals for their forests,

and for the political feasibility of their plans. The

number of administrative appeals and lawsuits is one

measure of political feasibility, but the number can

be reduced by simply postponing controversial

decisions to another forum or to a successor. Thus,

additional measures of effective public involvement

are needed to assess managerial performance in this

area. Another difficulty is that managers and their

staffs are likely to be predisposed to favorable

evaluations of their performance, thus limiting their

impartiality in monitoring forest plan implementation. Finally, the habitual transfers of managers can

reduce their accountability; one manager and/or

planning team may develop a plan which must then

be implemented by a successor. These problems can

be minimized with distinct monitoring teams and a

thorough description of planning participants, issues

and concerns, and past and current conditions. The

direction and goals in the forest plan also must be

clearly specified.
Chapter 10

Relationship of Forest-Level NFMA

Planning 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.. .**. *.*. ... .*. **. . .*...**.......**. .** *..*""".*""""""""""*""'""

179

179

180

181

181

182

183

183

184
Chapter 10

Relationship of Forest-Level NFMA Planning

to National RPA Planning

INTRODUCTION

The Forest and Rangeland Renewable Resource

Plannning Act of 1974 (RPA) establishes a strategic

planning process for an integrated, national examination of renewable resource conditions and opportunities for all forests and rangelands. The strategic

planning process envisioned in RPA is structured

around the preparation of four documents: the RPA

Assessment, the RPA Program, the Presidential

Statement of Policy, and the Annual Report. The

RPA Assessment is to provide information on

renewable resources--conditions and outputs, interrelationships, and present and future supplies and

demands. This information serves as the basis for the

RPA Program and the development of directions and

goals. The Presidential Statement of Policy, transmitted with the Program to Congress, guides formulation of annual budget requests. The Annual Report

informs Congress of the Forest Service’s progress in

implementing the RPA Program. Together, these

four documents enable the Forest Service to develop

along-term strategic plan to guide present and future

management decisions.

RPA also establishes a strategic planning process,

at the local level, that stresses an interdisciplinary

approach and public involvement. The National

Forest Management Act of 1976 (NFMA) amended

the original RPA legislation by providing substantial additional direction in preparing land and

resource management plans for the national forests.

These forest plans are intended to set long-term

direction for on-the-ground management activities,

including desired future resource conditions and

subsequent management actions to achieve those

conditions. In contrast to the national scope of the

four RPA documents, the forest plans guide management activities at the local level. The plans take into

account local situations, capabilities, and opportunities, and attempt to balance local resource uses and

values to accommodate the public’s interests.

If the strategic planning process envisioned in

both RPA and NFMA is to be effective, national

direction and goals must mesh with local capabilities. The RPA documents must incorporate information from the local level on resource availability and

conditions as well as on public opinion, desires, and

concerns. The information on local interests and

capabilities must be available for use in the national

analysis. Only with this meshing of national and

local planning can the forest resources be managed

sustainably for the future.

THE CURRENT

RPA-NFMA LINKAGE

Congress did not envision a clear, direct system

for meshing national and local planning efforts

(329). The RPA and NFMA planning processes have

been evolving slowly, however, to become more

intertwined. Historically, the Forest Service has

approached planning as a hierarchical process that

allocates resource output targets from the RPA

Program to the regions, and from the regions to the

forests (206). This approach contrasts with the

description of the linkage between RPA and NFMA

in the Forest Service regulations as:

. . . essentially iterative in that the information from

the forest level flows up to the national level where

in turn information in the RPA Program flows back

to the forest level (36 CFR 219.4(a)).

In 1989, Forest Service Chief Dale Robertson

(206) testified that the 1990 RPA process was

influenced by an integrated approach, with “more

careful consideration of the resource opportunities

as developed in the forest plans. ” This integration

was accomplished by using data from the plans in

the RPA Assessment and by building RPA Program

strategies using forest plan standards and guidelines.

Robertson stated that, because most of the forest

plans are now complete and more comprehensive

than earlier plans, data from the forest plans were

used extensively in the 1990 Program. Thus, the

1990 program may mark the beginning of an

iterative exchange of information, from the forests to

the national level and the national level to the

forests, contemplated in the regulations.

The historic pattern of top-down targets from the

RPA Program to the national forests was possible

before the completion of the national forest plans

–l79-

7q7.WIA II - q7 _ 7
180 . Forest Service Planning: Accommodating Uses, Producing Outputs, and Sustaining Ecosystems

only because of lack of information. Many forests

took 10 to 15 years to complete their frost plans under

NFMA, providing little information from the local

level to feed into the national process. The lack of

final forest plans permitted the top-down flow of

information to dominate, and led to allocation of

resource output targets from the national level to the

regions and forests.

RPA target allocations are difficult to mesh with

NFMA planning because: 1) targets are set only for

outputs and 2) allocated targets may be infeasible.

Output targets are not necessarily incompatible with

local level strategic planning, but forest managers do

not have the measures to determine annual outputs

for all resources. (See ch. 6.) Annual timber production can easily be measured, and is directly under the

control of the managers, but recreation use, water

flows, wildlife populations, and other uses and

outputs are less easily measured, and less readily

governed by managers. Furthermore, the RPA Program has not established effective targets-those for

which managers can be held accountable-for

resource conditions of forests and rangelands. Thus,

RPA targets have become synonymous with national timber sale targets.

Equal treatment of all resources could be accomplished by setting national targets for all important

outputs and conditions. This approach would require

developing measures for nontimber values-an

admittedly difficult task. Meaningful production and

condition goals for recreation, range forage, water,

wildlife, and fisheries have not been established, and

reported accomplishments might be impossible to

verify or to evaluate objectively (277). Nonetheless,

accountability standards for all important forest and

rangeland outputs and conditions are a prerequisite

if the RPA process is to establish broad and balanced

direction for the Nation’s renewable resources.

Even if acceptable national targets are established

for all significant outputs and conditions, the allocated RPA targets probably would not match the

targets set in forest plans. NFMA plan targets are

developed locally, with information on resource

conditions and interactions and with substantial

public input. The dilemma arises as to how to decide

between allocated RPA targets and NFMA plan

targets. Should national targets override the NFMA

planning process when so much time and effort goes

into local planning? Allocated RPA targets could

make local analysis and public involvement in

NFMA planning useless and ineffective, because

targets are set by people removed from the local

resource conditions and public desires. Alternatively, should the local planning process ignore the

regional, national, and global concerns reflected in

the RPA targets? NFMA planning targets could

result in missed opportunities or regional dislocations not considered locally.

A second, and more serious problem in trying to

mesh RPA targets with NFMA planning, is that

allocated RPA targets maybe infeasible, despite the

resource capability information in the NFMA plans.

In past RPA Programs, resource production goals,

especially for timber, have been a reflection of

projected national demand more than a reflection of

the resource capabilities to actually meet that

demand (277). Even before NFMA was enacted,

participants of a national symposium organized by

the Forest Service at Pajaro Dunes, CA, discussed

the need for data aggregation to proceed in a local

‘‘bottom-up’ approach (192). In addition, even with

aggregated local data from the forest plans, national

analyses of capabilities and opportunities necessarily lack information on site-specific resource interactions and conflicts. RPA analyses, therefore, will

typically overestimate the productive potential of

the lands being analyzed (72). (See ch. 7.) Thus, the

national planning process under RPA is likely to

overstate the opportunities for producing outputs

from the national forests.

DIRECTION AND FLOW OF

INFORMATION

The conflict between allocated RPA targets and

directions established in NFMA planning might be

alleviated if the flow of information between the

forest plans and the RPA documents is continuous

and two-directional. Precedent has been set for a

process that is based on capabilities set locally, with

general guidance from the top. In a 1988 court case,

a Federal district court ruled that while production

targets under a timber management plan are important goals, they are not legally enforceable decisions

(277). The Chief of the Forest Service expressed

agreement with this decision in an internal memo to

the regional foresters (207).

The compatibility of output potential determined

at the local level, and output goals determined at the

national level, must be discussed and planning

adjusted depending on national and local interests,
Chapter 10--Relationship of Forest-Level NFMA Planning to National RPA Planning ● 181

resource sustainability, and budget allocations. This

approach would shift the RPA Program’s emphasis

from setting hard targets for the national forests to

setting an overall direction for the Forest Service--

for Research, State and Private Forestry, and International Forestry as well as for the National Forest

System. The Program would guide national policies

and identify considerations and approaches for

NFMA planning. The NFMA plans would determine capabilities based on resource inventory and

monitoring, public input, and local managerial

expertise.

To , summarize, the Forest Service regulations

describe the information flow among the RPA

documents and the forest plans as iterative. Information from the plans is used in compiling the RPA

Assessment, and the plans and the Assessment

contribute to the RPA Program, which then provides

guidance for the forest plans. The problems created

by this process could be alleviated with a continuous

and interactive information flow among the four

RPA documents and the forest plans.

NFMA Planning and the RPA Assessment

Data gathered to prepare the national forest plans

and to monitor plan implementation provide basic

information on resource conditions and predicted

outcomes of proposed management actions, and on

opportunities and limitations for expanding the uses

and outputs of the national forests. Forest planners

should be aware of resource demands outlined in

previous Assessments and compare local assessments of physical, biological, and economic capabilities of the land with the national assessment, to

assure that the conditions and possibilities considered in planning address national concerns (277).

Standardized procedures and measures for inventories and monitoring can improve communication

and minimize the costs of developing analytical

models-each forest can take advantage of computer capabilities and models developed for the

entire agency (51). (See also ch. 6.)

The RPA Assessment can assist forest-level

planning by serving as a source book for planners.

First, the Assessment provides information on methods used on national forests, private, and other

public lands to collect data on resource outputs,

conditions, and trends. This information can help

planners design inventories and monitoring activities on their forests so that data will be compatible

with previous inventories and with studies in progress. Measures used on the national forests must also

be comparable to measures used on private and other

public lands so that data can be aggregated and

compared. Coordination of data measures allows

information from the national forests and from

private and other public lands to be used in a

comprehensive analysis. These data are then available for national use in the RPA Assessment,

Program, and Annual Report.

In addition, the RPA Assessment (and the supporting data) is a source of information for forest

planners to consider in examining alternatives for

their national forests. The Assessment is to describe

the existing resource conditions and outputs from

private and other public lands, as well as from the

national forests. Forest planners can use the Assessment database to assess the extent to which various

regional, national, and global concerns are being

addressed on the lands surrounding their forest, and

thus can assess the need for addressing such

concerns in their forest plans. The RPA Assessment,

therefore, is a source of information on inventory

and monitoring measures and methods and on the

conditions and outputs from lands surrounding the

national forests.

NFMA Planning and the RPA Program

The forest plans can contribute to the RPA

Program by providing information and guidance on

the public’s preferred management alternatives for

the National Forest System. The forest plans are

developed with substantial public input, and thus

should describe locally acceptable management

direction. Furthermore, the NFMA planning process

identifies public issues and concerns relevant to the

management of the national forests. Issues and

concerns that are widespread at the local level

should receive special attention in the Program. For

example, a national policy on below-cost timber

sales might demonstrate agency responsiveness to

public concerns. In essence, NFMA plans are part of

the public’s participation in the RPA process.

As a strategic plan, the Program needs to set

direction for all planning on the national forests as

well as for research, cooperative assistance, and

international programs. The Program, however,

should not override local decisionmaking. Instead, it

can augment NFMA planning by addressing regional, national, and global problems not identified
182 . Forest Service Planning: Accommodating Uses, Producing Outputs, and Sustaining Ecosystems

or considered locally. The Program can then include

issues and concerns to be considered in amending

and revising the forest plans, with a clear explanation of why such issues are of regional, national, or

global concern and should be addressed in national

forest management. This interpretation of the influence of the RPA Program on local planning is

patterned after a theme of “firm central direction

and maximurn individual autonomy’ ‘—a theme

common to effective organization in the private

sector (195). This view was expressed by Chief

Robertson in his 1990 testimony, stating that resource output targets will be replaced by more

flexible, general guidance from the RPA Program

(206).

Strategic planning does not require the elimination of national targets. In fact, targets may be

critical to reaching stated goals for the various

resources. Hard national targets, however, can effectively negate local decisionmaking, if targets are se t

only for certain outputs and only for the national

forests. Such targets also tend to discourage an

interactive flow of information from the local level

to the national level and thus run counter to

functional strategic planning and the iterative process. Alternatively, national output and condition

targets can be used to identify impending or

potential problems that are to be considered in

national forest planning, in setting research priorities

and in determining the financial and technical

assistance needed by States and private landowners.

NFMA Planning and the Budget Process

The forest plans are intended to serve as the basis

for developing the agency’s annual budget proposal

(217). However, the budget requests from the forests

cannot simply be added together to arrive at a grand

total for the National Forest System, because the

forests have used different assumptions about possible budget levels in their NFMA plans. (See ch. 8.)

Currently, the forests identify the appropriate projects for implementing the forest plan. These multipleuse projects must then be converted into budget

requests by resource activity, and the budgets for

each resource activity are subject to modification by

the administration and Congress.

The Forest Service budget request for the National

Forest System must be balanced against overall

spending constraints and management priorities.

According to Chief Robertson (206), the rate of

forest plan implementation-and the mix of projects

carried out under the plans-depends on the annual

Federal budget process:

[The] forest plans are strongly linked to and

dependent on the national budget process. As we

develop our annual agency budget request, we

carefully consider the needs documented in the

forest plans in light of competing agency priorities

and constraints. Ultimately, the rate at which we are

able to implement each plan-and the relative

emphasis given to each component of the plan--

reflects national priorities and constraints that are

resolved as the President proposes a budget and the

Congress appropriates funds.

Congress appropriates funds by resource activity.

The appropriations are then allocated to the regions,

and subsequently to the forests. The appropriations

by resource must be converted back into multipleuse projects, not an easy task because it is unlikely

that the appropriations will match the balanced mix

of resource activities needed to implement the forest

plans.

A better flow of information between the forest

planning and the budget and appropriations process

is needed for implementing the forest plans. Congress needs accurate information on the likely

outputs and conditions that will result from implementing the plans with a given level of appropriations. Congress also needs information on the

improvements possible with increased tiding, and

on the consequences of reduced funding. Furthermore, the local publics need to know how the forest

plan will be implemented, if the full funding called

for in the plan is not appropriated. Thus, to be

integrated with the budget and appropriations process, the forest plans must contain information on the

likely outputs and conditions under a range of

budgets, including both the most likely and the most

desirable budget levels.

The budget and appropriations process also must

be better integrated with forest planning. The current

structure of appropriations by resource activity is

inconsistent with the integrated, multiple-use management direction established in the plans. Congress

may object to reducing the current budget details,

fearing a loss of control over the Forest Service

budget. However, actual expenditures and accomplishments often differ, sometimes substantially,

from the appropriations and from the reported

expenditures and accomplishments. Furthermore,
Chapter 10-Relationship of Forest-Level NFMA Planning to National RPA Planning ● 183

special accounts and trust funds account for more

than a third of the Forest Service budget, but the

substantial agency discretion over the size and use of

these funds occurs with little congressional control

or oversight. Thus, Congress has, in fact, already lost

some of its apparent control in the appropriations

process. Congress could reestablish control over the

Forest Service budget while allowing the implementation 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 permanent appropriations; and

3. requiring full disclosure of expenditures and

unit costs for significant activities-regionally

and fictionally.

NFMA Planning and the Annual Report

Monitoring of the forest plans can provide information to be presented in the Annual Report on the

expenditures and results of management activities

on each national forest. This information can be used

to compare the performance of forest supervisors

and regional foresters, and thus can serve as an

incentive for the Forest Service to make sure its

efforts are balanced and efficient.

Peer pressure is an important component of

quality performance. Thus, monitoring of forest plan

implementation should provide information for the

Annual Report on what each forest is doing and how

well management activities have been implemented.

Consistent reporting is necessary so that data can be

aggregated and compared. Unit cost information is

important, especially for certain critical activities

and results, such as reforestation success, timber sale

preparation and harvest administration, and wilderness quality improvements. Furthermore, as discussed earlier, measures are needed for all the

important outputs and conditions, to assure that all

goals are being achieved; finally, management

activities, such as range improvements and watershed rehabilitation, must be related to the outputs

and conditions of interest to Congress and the public.

A third connection between forest planning and

the Annual Report may be the identification of

important issues that arise quickly, in the time

between RPA Programs. To address rapidly emerging issues in a timely fashion, the issues can be

discussed in the local context and included in

Annual Reports. In this way, forest planning and the

Annual Reports can serve as issue scoping for each

RPA program, and as a basis for considering new or

revised policy direction for national forest management.

NFMA Planning, RPA, and the

Role of the Regions

In the RPA and NFMA planning processes

described in this OTA assessment, the regional

offices serve three main purposes: to aggregate data,

to allocate budgets, and to coordinate and facilitate

problemsolving of regional scope. 1 Budget and

resource data from all of the national forests are too

unwieldy to accommodate directly at the national

office. The regional offices can aggregate these data

and present them to the national office in a manageable form. The regional offices also work with

budget decisions from the national level, allocating

budgets to the forests.

The regional offices’ third role, to coordinate and

facilitate problemsolving of regional scope, maybe

especially important when problems involve several

forests as well as State, private, and other public

lands. The regions can identify issues common to

several national forests, and can assist in coordinating responses and identifying issues that need to be

addressed nationally, in the RPA planning process.

The regional offices can also serve as a focal point

for coordination with State agencies that have a

stake in national forest management, including

agencies that regulate forest practices, that manage

wildlife populations, and that enforce water rights

and water quality standards.

If the RPA Program is not seen as a document

providing hard output targets and budgets to the

forests, the regions would not be required to serve as

a liaison in these areas. Rather, they could provide

coordination between local decisionmaking (as the

major impetus behind planning) and national policy

guidance. The regions could assist in finding ways

to deal with regional disputes and conflicting

interests before they are brought to national attention.

IRe@o~ offices ~doubt~ly sme o~er functions, as well, but this section focuses solely on tieir role ~ WA ~d NFMA planning.
184 . Forest Service Planning: Accommodating Uses, Producing Outputs, and Sustaining Ecosystems

CONCLUSION

Concern over land and resource capability and

sustainability has contributed to the debate over

centralized, top-down planning versus decentralized, forest-based, bottom-up planning (277). Resource capability information developed at the local

level was intended to provide the foundation for

RPA planning; at the same time, national objectives

are essential to strategic planning and setting longterm goals. National and forest level information

‘‘address the nations’s resources demands and

recognize natural and practical limitations

of the land and forests to meet those demands’

(277).

Binding targets set at the national level in past

RPA Programs have resulted in a concentration on

timber outputs, at the expense of considering other

outputs and conditions. Furthermore, national analyses are likely to overestimate productive potential,

because site-specific resource interactions are necessarily lost in aggregating data on local capabilities.

Replacing hard targets with general guidance and

flexible goals would lessen the emphasis on topdown planning and allow for a more iterative

process, as prescribed in the regulations.

A two-directional, interactive exchange of information between local forest planning and national

RPA planning would encourage resources to be

managed for realistic and desired goals and longterm sustainability. The forest plans can provide

information: on resource capabilities for the RPA

Assessment, on public desires for national forest

management for the RPA Program, on opportunities

and likely results for the annual budget, and on the

results and costs of management for the Annual

Report. The Assessment database can inform planners about conditions and outputs from neighboring

lands, and about measurements and methods for

inventorying and monitoring. The Program can provide policy direction for considering regional, national, and global issues and concerns. The annual

appropriations determine the extent of implementation of the forest plans. And the Annual Report

allows managers to compare their performance in

implementing the forest plans with the performance

of their peers. Thus, by improving the flow of

information between local NFMA planning and

national RPA planning, the national forests can be

managed to achieve local desires, address national

needs, and assure the long-term sustainability of the

forest ecosystems.
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Index
Index

Administrative appeals, 5,65-66,83,95-99, 105

Advisory committees, 20, 80

Allegheny National Forest, 168

Allowable timber sale quantity (ASQ), 18,97, 127-128, 131,

132, 133, 146

Alternative dispute resolution (ADR), 92-94,95,98

Annual reports

for national forests, 12, 22, 115

Report of the Forest Service, 25, 172, 174

RPA, 9,40, 143, 179, 183, 184

Appropriations

forest plans and, 12,23,52,86, 169, 182-183

. permanent, 154, 155-156, 159

resource-oriented, 8, 12, 23, 24-25, 86, 158, 182-183

Arapaho-Roosevelt National Forest, 121

Banzhaf, William, 163

Barrett, Frank, 37

Beaverhead National Forest, 154

Best Management Practices (BMPs), 70, 116

Biological diversity

data inadequacies, 6, 123

legal requirements, 6, 115, 119-120, 123

in NFMA planning, 120-121

Biological modeling, 117-118

Biologists, 165, 175

Bitterroot controversy, 17,40,54,79,82,87

Bitterroot National Forest, 40,79, 112, 114, 115, 116, 120

Belle Report, 40,42,82,85,86

Boundary Waters Canoe Area, 39

Budget

differing assumptions, 8, 12, 13,23,25, 151-152, 158,

182

effect on planning decisions, 12,23-24

end-results budgeting, 8, 153-154

forest plans and, 8, 12-13,23-27,52,53,86, 151-156,

173-174, 182-183

off-budget funding, 154-156

policy options, 12-13,23-27, 183

reprogr amming, 153

resource 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, 144

Bureau of Land Management (BLM), 13,26-27,98, 100, 150,

155, 170

Carter, Jimmy, 78

Chattahoochee/Oconee National Forest, 92

Chequamegon National Forest, 116, 120, 122

Chugach National Forest, 66,92

Church Clearcutting Guidelines, 40

Cibola National Forest, 113, 122

Clarke-McNary Act of 1924,35

Clean Water Act, 70, 102

Clearcutting, 33,4041,79, 135

Cleveland, Grover, 34

Coconino National Forest, 112, 114, 115, 116, 120, 131

Community stability, 7-8, 103, 148-151, 158

Computer models. See Technologies for planning

County payments, 7-8, 12, 13,23,26-27, 151, 154, 156

Critical habitat, 71-72

Data collection. See Inventories; Monitoring

Database management systems, 130

Dixie National Forest, 112, 115

Dominant use, 4,43-46

Economic analysis. See also Budget

of economic impacts, 7-8, 148-151

efficiency, 143-147, 156-157

in endangered species determinations, 71

equity, 143, 147-148

legal requirements, 143

technologies for, 7, 130

Ecosystems approach

constraint rather than goal in FORPLAN, 7, 135

inventory and monitoring, 10-11, 18-19,21,24-25, 110, 119,

122

MUSYA and, 10,4749

need for, 4,6,9, 10-11, 17-19,21,24-25,28,4749, 110, 119,

122

NEPA and, 10,62

NFMA and, 65

Eisenhower, Dwight D., 37

Eldorado National Forest, 112, 115, 116, 120

Endangered species. See specific species; Wildlife

protection

Endangered Species Act of 1973,33,70-72, 101

Engineers, 164-165

Environmental impacts, 61-62,78, 129-130

Environmental Protection Agency, 70, 121

Fernow, Bernard, 163

Fish arid Wildlife Service, 33,46,71,72,98

Ford, Gerald, 80

Forest and Rangeland Renewable Resources Planning Act of

1974. See RPA

Forest managers. See also Human resources

accountability, 65-66, 87-88, 173, 174-175, 176

constraints, 85-86

effects of bias favoring outputs, 11, 21, 172, 173

forest plan implementation, 52, 174

NFMA and, 65-66

Forest plans

as a baseline for RPA planning, 9-10, 13-14,27-28,

180-184

development, 17-21,63-64, 173-174

implementation, 9,21-23,52, 173-174

purpose, 4, 179

Forest Service. See also Human resources

–203–
204 ● Forest Service Planning: Accommodating Uses, Producing Outputs, and Sustaining Ecosystems

agency vs. employee values, 9, 169-171, 176

history and organization, 3, 35

public involvement efforts, 81-86,91

response to social change, 8, 169-170

Foresters, 163-164, 166-167, 175

FORPLAN. See also Linear programming

criticisms of, 3, 7, 127, 136-137, 138

description, 7, 127, 132-133

development and selection, 7, 18, 131-132, 138

as an economic efficiency model, 7, 144-147, 156-157

future options, 11,20-21, 139

as a planning tool, 136-137, 138, 139

strengths and weaknesses, 7, 18, 20, 133-136, 138, 156-157

timber focus, 18, 117-118

General Accounting Office (GAO), 8,96,97,98, 153

Geographic information systems (GIS), 6, 11, 118, 129, 130,

138

Gila Wilderness, 38

Goals and objectives

achieving, 49-53

government ownership rationale, 42-43

historical development, 34-42

setting, 50, 63

Government ownership rationale, 42-43

Grazing, 35-37,60

Hatfield, Mark, 77

Human resources

diversity, 137, 167-169, 175-176

employee vs. agency values, 9, 169-171, 176

foresters, 163-164, 166-167, 175

interdisciplinary teams. See Interdisciplinary approach

performance and rewards, 171-175, 176

professionalism, 84-85, 163-167

professionals other than foresters, 164-165, 175

transfers, 174-175

Humphrey, Hubert, 39,40,41,79-80

Idaho Panhandle National Forest, 113, 114, 116, 122

Impact assessment technologies, 129-130

IMPLAN, 7,20, 130, 138, 148, 150

Indicator concept, 121

Indicator species, 6, 121-123

Information base, 10-11, 18-19,51-52

INFORMS, 130-131

Input-output analysis, 7, 20, 130, 138, 148, 149

Integrated systems, 130-131

Interagency cooperation, 102-103

Interdisciplinary 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

Inventories

compliance with requirements, 114

funding and, 11, 111

integrated, multiresource, 6, 109, 110, 117

legal requirements, 111-112

objectives, 112

policy options, 18-19,51

problems with, 6, 10-11, 18-19,21,51, 110-111, 112-114,

117-118, 123

quantity and quality of data, 113

statistical requirements, 110-111

timeliness of data, 51, 113-114

use of, 109

Investment, 147

Jefferson National Forest, 92

Johnson, Norman, 134

Joint production, 4,42,4346

Judicial review, 5-6, 99-101

Klamath National Forest, 154

Knowledge-based systems, 130

Knutson-Vandenberg (K-V) Fund, 8,23-24,25, 26, 154, 155,

156, 159

Land and resource allocation technologies, 129

Legal framework. See also specific laws

concerns about, 59-60, 72-73

Forest Service mission and authority, 60-66

legal constraints, 66-72

Legislative direction, 10, 18

Leisz, Douglas, 132

Leonard, George, 149

Linear programming, 6, 128-129, 131, 132, 137-138. See also

FORPLAN

Litigation, 3,5-6, 17,33,73,79,99-101, 105, 174

Local concerns, 103. See also National vs. local planning

Lolo National Forest, 168

Management indicator species. See Indicator species

McClure, James, 77

Mission ’66, 37

Monitoring

compliance, 115-116

funding, 111

indicator species, 122-123

integrated, multiresource, 6, 109, 110, 117

legal requirements, 115

levels of, 116-117

policy options, 11-12,21-23

problems with, 6, 11,21-23, 110-111, 115-117

public involvement, 12, 22-23

purpose of, 6,21, 109

statistical requirements, 110-111

Monongahela decision, 17,33,40,54,61, 79, 82

Monongahela National Forest, 40,79,92

Mt. Hood National Forest, 154

Multiple use, 4,35, 43-46

Multiple-Use Sustained-Yield Act of 1%0 (MUSYA), 3,4,5,

17, 18,35-38,41,43,46,61, 78, 101, 143

Multiple-Use Sustained Yield Calculator (MUSYC), 131

Nantahala/Pisgah National Forest, 112, 115, 116, 120

National Environmental Policy Act of 1969 (N EPA), 3,4,20,

78-79,97, 165

National Forest Management Act of 1976 (NFMA)

criticisms of, 17, 33, 50, 77
Index . 2 0 5

economic analysis requirements, 143

forest plan requirements, 63-64

guidelines for timber management, 18,64-65, 127-128

inventory requirements, 111-112

legislative history, 3, 17,33,4042,63,79-80, 179

management discretion, 65-66

monitoring requirements, 115

national RPA planning and, 9-10, 13, 34, 41, 49, 63,

179-184

public involvement and, 3,65,77,79-81

regional office role in planning, 183

regulations implementing, 80-81

National Forest System

creation, 34-35

trust fund concept, 5,48

National forests

Allegheny National Forest, 168

Arapaho/Roosevelt National Forest, 121

Beaverhead National Forest, 154

Bitterroot National Forest, 40, 79, 112, 114, 115, 116, 120

Chattahoochee/Oconee National Forest, 92

Chequamegon National Forest, 116, 120, 122

Chugach National Forest, 66,92

Cibola National Forest, 92, 113, 122

Coconino National Forest, 112, 114, 115, 116, 120, 131

Dixie National Forest, 112, 115

Eldorado National Forest, 112, 115, 116, 120

Idaho Panhandle National Forest, 113, 114, 116, 122

Jefferson National Forest, 92

Klamath National Forest, 154

Lolo National Forest, 168

Monongahela National Forest, 40,79,92

Mt. Hood National Forest, 154

Nantahala/Pisgah National Forest, 112, 115, 116, 120

Nebraska National Forest, 92

Nicolet National Forest, 112, 115, 116, 120

Ochoco National Forest, 86

Ouachita National Forest, 112, 120

Rio Grande National Forest, 92

San Juan National Forest, 112, 113, 115, 116, 120

Shoshone National Forest, 121

Siskiyou National Forest, 112, 113, 114, 115, 120

Tongass National Forest, 66, 155

White Mountain National Forest, 80

Willamette National Forest, 154

National Park Service, 35, 37, 98, 166

National vs. local planning, 9-10, 13-14,27-29, 179-184

Nebraska National Forest, 92

Nicolet National Forest, 112, 115, 116, 120

Nixon, Richard, 78

Nonuse values. See Outputs and uses vs. nonuse values

0 & c Act of 1937,47

Ochoco National Forest, 86

Office of Management and Budget (OMB), 134, 144, 153

Old-growth forests, 5,17,33,44,51,53,100, 101,120,131,133,

135, 138. See also Timber resources management

Organic Act of 1897,3,4,5,33,34-35, 40-42,60-61, 101, 148

Organizational factors, 8-9, 163-176

Ouachita National Forest, 120

Outputs and uses vs. nonuse values

bias favoring outputs, 4,6,9, 10, 17-18,28,4749,

163-164, 172-173

in FORPLAN, 7, 18, 135

MUSYA and, 18

NFMA and, 18

policy options, 10-11, 14, 17-21,28-29

setting values, 144, 145-146

Payments in Lieu of Taxes (PILT), 13,26-27

Performance rewards, 171-175

Pinchot, Gifford, 47,60, 163, 164

Policy options, 10-14, 17-30

Present net value (PNV), 130, 132, 144

Presidential Statement of Policy, 9,40, 179

Privatization of Federal lands, 44-45

Professionalism, 85, 163-167

Public involvement

accountability and, 22, 87-88

cooperation and collaboration, 86-95

diversity and, 167

Forest Service efforts, 81-86,91

ineffectiveness, 4-5, 20, 81

legal requirements, 20,77-81, 104

means, 5

measuring effectiveness, 91-95

models of effectiveness, 88-91

in monitoring, 12, 22-23

NEPA and, 20,62,77,78-79

NFMA and, 3, 20, 65, 77, 79-81, 181

policy options, 11, 20

reasons for, 5, 50-51, 87-88

reasons for difficulties, 83-86, 104, 166-167

State, tribal, and local governments, 101-103

Reagan, Ronald, 81

Recreation, 9,35,36-37,46, 172

Red-cockaded woodpeckers, 17,33, 53,70

Reforestation Trust Fund, 26, 154

Regional office role in RPA and NFMA planning, 183

Report of the Forest Service, 25, 172, 174

Resource allocation technologies, 129

Resource Capability System (RCS), 131

Resource scheduling technologies, 128-129

Resource simulation models, 6, 129-130

Rio Grande National Forest, 92

Road construction, 143, 157

Roadless Area Review and Evaluation (RARE I), 40, 68

Roadless Area Review and Evaluation (RARE II), 68-69, 114

Robertson, Dale, 59,72,82-83, 179, 182

RPA (Forest and Rangeland Renewable Resources Planning Act

of 1974)

legislative history, 3,3940,63, 179

policy options, 13-14,27-29

purpose, 3,39-40,49, 179

regional office role in planning, 183

relationship to NFMA planning, 9-10, 13, 34, 41, 49, 63,

179-184

RPA Assessment, 9, 143, 179, 181, 184

RPA Program, 9,34,49, 143, 152, 173, 179, 180, 181-182,

183, 184
206 . Forest Service Planning: Accommodating Uses, Producing Outputs, and Sustaining Ecosystems

San Juan National Forest, 112, 113, 115, 116, 120

Scientific conservation paradigm, 163-164, 165-166

Shoshone National Forest, 121

Siskiyou National Forest, 112, 113, 114, 115, 120

Society of American Foresters (SAF), 163, 164

Special accounts and trust funds, 8, 12, 13,23-24,25-26,

154-156, 182-183

Spotted owl, 5, 17, 18-19,33,51,53,70, 100, 101, 102

State, tribal, and local government involvement, 101-103,

105-106

State responsibilities, 101-102

Strategic planning principles, 4,34,49-53,54-55

Sustained yield, 4,4749, 149

Sustained Yield Forest Management Act, 47

Targets, 9-10, 11, 13, 14, 19,27,28-29, 172-173, 179-180,

182

TEAMS, 130-131

Technologies for planning. See also FORPLAN

policy options, 11, 20-21

relevant planning decisions, 127-128

types, 6-7, 128-131

Ticknor, William, 164, 166

Timber Assessment Market Model, 146

Timber Resource Allocation Model (Timber RAM), 131, 132

Timber resources management

administrative appeals, 96,97-98

clearcutting, 33, 40-41, 79, 135

community stability and, 7-8, 148-151

county payments, 7-8, 12, 13, 23, 26-27, 151, 154, 156

emphasis on, 10-11, 12, 17-18, 23, 35, 110, 117, 163-164,

170, 172, 184

litigation, 33,4041, 100

NFMA guidelines, 18,64-65, 127-128

policy options, 10-11, 17-21

receipts, 151, 154, 158

‘rich’ and ‘poor’ forests, 154

technologies for, 6, 18, 117-118

trends, 35-37

Timber Sale Program Information Reporting System (TSPIRS),

25

Timber Salvage Sale Fund, 8,24,25,26, 154

Tongass National Forest, 66, 155

Trust fund concept of National Forest System, 5,48,55

User fees, 60

Wallinger, Scott, 164

Watershed protection, 18,22,35,46,60,70, 153, 172

Weeks Law, 35

White Mountain National Forest, 80

Wild and Scenic Rivers Act of 1968,67-70, 102

Wilderness Act, 38-39,66-67, 101-102

Wilderness areas, 37,68-69, 133, 146, 154, 172

Wildlife protection, 18, 22,46, 60, 70-72. See also

Biological diversity; Inventories; Monitoring; specific

species

Willamette National Forest, 154

Winding Stair Mountain National Recreation and Wilderness

Area Act, 120-121

IJ. s. GOVERNMENT PRINTING OFFICE : 1992 0 - 2gT-gOd QL 3