INTERIOR COLUMBIA BASIN ECOSYSTEM
The Leading Edge
"The Implementation Team is here to ensure that decisions based on the Final EIS will be feasible at the field level. By working through the processes early on, it will help in achieving the overall goals of the Project."
Implementation Team Leader
Thinking Ahead: From Plan to Implementation
While public comments will guide us from Draft to Final Environmental Impact Statement (EIS), we are thinking ahead to the implementation stage of the Interior Columbia Basin Ecosystem Management Project (Project). In May 1996, the Executive Steering Committee (ESC) recognized the need to develop a strategy that would help in the transition from a Record of Decision (ROD) to implementation at the local level. Through this recognition they formed an "Implementation Team" for the Project.
The Implementation Team's focus is on ensuring that a coordinated and consistent integration with existing land use plans and the decisions that will result from the Project occurs. The team also assists in bridging the gap between the broad-scale and local information. The Implementation Team will ultimately help in facilitating consistent and collaborative application of the Project decisions to the National Forests and Bureau of Land Management (BLM) districts.
The team is staffed with representatives from each Forest Service Regional and BLM State Office in the project area, plus representatives from the National Marine Fisheries Service, U.S. Fish and Wildlife Service, and the Environmental Protection Agency. The team also has members that represent the Project's Tribal, Science and EIS Teams. Rick Tholen is the Implementation Team Leader, coming to the Project from the BLM's Idaho State Office.
Tholen likens the role of the Implementation Team to that of the BASF Company whose slogan is, "We don't make a lot of the products you buy. We make a lot of the products you buy better." As Tholen notes, the team was not designed to make decisions, but to make sure that the concepts presented in the Draft Environmental Impact Statements (EISs) are feasible at the ground level when the decisions are documented in a Final EIS and ROD.
Tholen also recognizes what a monumental task it will be to assure the effective and efficient implementation of such a large and complex effort.. He believes that it is essential that his team work hand-in-hand with other project teams and field office staff, as well as coordinate the efforts closely with other government representatives (local, Federal, State and Tribal entities) and the public. Through this effort it will ensure that the best design to get from decision to on-the-ground implementation is in place when the Record of Decision occurs.
To date, the Implementation Team has made significant progress with several assignments, including:
These have been incorporated into the subbasin review prototypes by the Implementation Team. This will help in more fully understanding how the subbasin reviews could be conducted to help achieve ecosystem management objectives.
Also, the Implementation Team has assisted in establishing two Regional Implementation Support Teams (RISTs) that will help in the transfer of information in the Final EIS and science documents to the field offices. The RISTs are comprised of existing BLM and Forest Service specialists in arenas such as forest ecology, aquatic ecology, and socio-economic science. In addition, each RIST has a team leader who is responsible for the overall operations of the team and ensures collaboration with other agencies, government representatives and stakeholders who have a vested interest in this transfer of information.
Through understanding this information early on in the process, the Implementation Team, as well as the ESC and project staff, anticipates a smooth transition from Final EIS and ROD to implementation.
A Hierarchy of Review
New processes for gaining information on the lands administered by the BLM and Forest Service are proposed within the Draft EISs for the Project . From Regional Plans to project analysis, there are several reviews, assessments and analyses that will need to be completed prior to implementing some site- specific projects on BLM- and Forest Service administered lands.
Some people perceive that these processes will improve the management of BLM- and Forest Service-administered lands. Others see this resulting in a "paralysis by analysis" syndrome - where the two agencies will be constantly reviewing, assessing and analyzing the lands they manage, but not implementing projects on-the-ground. These concerns will be carefully reviewed in the development of a Final EIS.
Meanwhile, similar sentiments expressed about the Northwest Forest Plan are instructive. The Northwest Forest Plan outlined new types of analysis: Ecosystem Analysis at the Watershed Scale (EAWS) and Late Successional Reserve assessments prior to implementing projects on lands west of the Cascades administered by the BLM and Forest Service. After four years, many involved in the process are finding that the results are providing a better understanding of the lands they are managing and focusing their work on those lands where opportunities exist.
As expressed in a recent speech by Sally Collins, Forest Supervisor of the Deschutes National Forest:
"We had tremendous concerns about the new levels of analysis required by the Northwest (Forest) Plan. What was the watershed analysis required? Was it a two-week deal or a one-year effort? Was it 16 pages or 1,600? What resources should we dedicate to it, especially not knowing what it might do for us?Collins went on to note that:
We had the same questions about Late Successional Reserve Assessments. To say nothing of the collaborative processes suggested by the Plan - Provincial Advisory Committees, interagency committees at all levels - a new bureaucracy in the making.
The list goes on. We ventured into what appeared to be a never-ending analysis paralysis, enough to make even the optimists among us skeptical. Then in the last two years, things started changing. On the Deschutes (National Forest), we have completed watershed analysis on most of the Forest, the recent ones being more focused and less expensive. We started seeing some value in the information we collected, and it began to shift how we thought about future decisions, the context within which we framed decisions, and how we prioritized the work to be done. This effort jump-started our movement into ecosystem management."
"For the first time since I've been on the Deschutes, we are ahead in our project planning for the year."
We here on the Interior Columbia Basin Ecosystem Management Project strongly believe that these additional levels of review and assessments, where appropriate, will assist the BLM and Forest Service in better managing the lands they administer.
One of the hardest concepts of this process for some people to accept is the need to adapt to change. But as the ancient Greek philosopher Heraclitus (535 B.C.) once said "nothing endures but change." As the world around us evolves and new information is made available we as agencies must adapt to meet those changes. This is a new way of doing business that will result in a better understanding and management of your BLM- and Forest Service- administered lands in the years to come.
The Concept of Scale
One of the most difficult, but important concepts one needs to understand in relationship to the Project, is the idea of "scale." Scale can be discussed at the spatial (geographic) level or at a temporal (over time) level. In having a better idea of scale relationships the reader can better understand various levels of analysis and/or assessments.
At the temporal scale the Project used several different scales of time. Short-term was considered to be a ten-year period, while the long-term was considered to be a 100-year period of time. The dynamics of the historical regime (historical range of variability) were assessed over a 400-year period to learn how historical systems changed with succession and disturbance through time.
At the spatial scale, the project area encompasses 144 million acres - approximately one-half of which are BLM- and Forest Service-administered lands. This is roughly equivalent to the land area of the state of Texas. For the project area, there are three levels of scale that we discuss in the analysis, these are:
Issues can occur at all three scales. They can be addressed at one or more scales depending on the need. An example is forest health, which is addressed in the Draft EISs at the broad-scale. The more one knows at each subsequently higher scale will assist in the development of a coherent strategy across the project area.
By going through the various levels of review, assessment and analysis will assist the BLM and Forest Service to better understand the limitations and capabilities of the land, which areas need attention, and which resources we should focus our energy and resources on in the future.
Subbasin reviews, as described in the Draft EISs, are intended to be a collaborative, intergovernmental process in which broad- to fine-scale information is compiled from already existing data and knowledge. A primary purpose of the review is to identify risks and opportunities within the subbasin. An example of a risk is areas with unstable soils prone to landslides. Whereas, an example of an opportunity may be where additional work to improve aquatic habitat exists.
A key component of this process is the concept of intergovernmental collaboration. Intergovernmental (local, State, Federal and Tribal entities) collaboration is an open and interactive process where all the parties involved work constructively together to address their collective needs and common goals. Collaboration denotes a higher level of partner involvement by the BLM and Forest Service than has traditionally been the case. This collaborative process is now occurring during the subbasin review prototypes and will continue when the Final EIS is implemented.
The project area is divided into 164 subbasins (averaging 800,000 to 1,000,000 acres). The reviews are intended to be a brief (2 to 3 week) review process. Subbasin reviews are intended to look at the ecosystem processes and functions in order to bridge the gap between the broad-scale information described in the Draft EISs and actual on-the-ground management actions. These reviews will help prioritize where EAWS should occur first and will help to identify priorities for finer scale analysis.
Currently, the Project is conducting seven prototype subbasin reviews across the project area to work out the details, and bugs, prior to implementation. The areas were selected to represent a range of conditions across the project area. These prototypes are being completed by interagency teams through the collaborative process.
As the prototypes are completed the Implementation Team will compile and evaluate the results from the process. From this information the team will assist in clarifying and/or modifying the direction in the Final EIS, and preparing a guide for implementation. By going through the prototypes, reviewing and modifying the information prior to issuing final guidance we anticipate that it will make for a smoother transition from theory to practice at the field level.
Ecosystem Analysis at the Watershed Scale (EAWS) is a refined assessment at the watershed level (15,000 to 150,000 acres). Those areas where EAWS are required are identified in the Draft EISs. EAWS will identify opportunities for projects and resource improvements on lands administered by the BLM and Forest Service. The EAWS will build upon the information provided through the subbasin reviews, plus through the additional gathering of information from the field to identify resource needs and opportunities.
Subbasin reviews and Ecosystem Analysis at the Watershed Scale will assist the BLM and Forest Service in identifying needs, risks, opportunities, and issues of the lands they administer. This in turn should result in better decisions that will benefit everyone involved in public land management.
The public comment period on the Draft EISs ended on May 6, 1998 after eleven months. Incoming mail increased as a final surge of comments came in from individuals, numerous interest groups, State governments, individual County and County associations, and American Indian Tribes as the comment deadline approached.
Written comments ran the gamut from pre-printed post cards, hand-written letters and messages, to large comment documents. Voluminous, appendix laden comments from specialists and professionals with major organizations and governments appeared in good number. Comments arrived via mail and E-mail, while some were hand delivered.
The 335-day comment period was necessary to respond to requests from many organizations, individuals and elected officials. This extension allowed more time for the public to read, comprehend and respond to the Draft EISs and accompanying Science documents. The comment period was extended three times, the final extension was necessary to respond to additional requirements included in the 1998 Interior Appropriations Act.
The Act directed the Secretaries of Agriculture and Interior to issue a report on the economic and social conditions of communities within the Project area and allow for a reasonable period of time for public comment on the report.
All comments postmarked by the May 6, 1998 deadline will be incorporated into the "content analysis" process on the Draft EISs. At this time between 80,000 and 90,000 comments have been received at the two project offices.
A team from outside the Project was hired for the content analysis process. These individuals are reading and categorizing each comment verbatim into a computer database for review by the EIS team. Comments received after the public comment deadline will become part of the Project's administrative record. These late comments, however will not be part of the content analysis process.
Public comments will drive the development of the Final EIS. The EIS Team will also examine other information which has come to light since the Draft EISs were written.