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Public Lands Foundation
Position Statement:
2010-17
The Role of Science in BLM Land
Management Decisions
September 9, 2010
Executive Summary
Science is important for supporting land
management decisions and helping to outline their consequences. The
Bureau of Land Management (BLM) must state clearly the role of science in
resource management decision-making and act accordingly. The Public Lands
Foundation (PLF) believes BLM needs to reinforce its institutional
commitment to the application of science to land management decisions.
Also, BLM would benefit from increased partnerships with public and
private science providers in making informed resource management
decisions. The use of the best available science is critical when
developing public land policy. A clearly understood and transparent
relationship between scientists and policy makers can be highly productive
and beneficial to BLM and the public.
Background
Land management is complex because the natural and social systems that are
affected are complex. Full consideration of relevant scientific
information can improve land management decisions. It can expand the
number of options considered, and it can increase the probability that
intended outcomes will be achieved. The Federal Land Policy and
Management Act of 1976 (FLPMA) directs BLM to use science in its
decision-making process:
In the development and revision of land
use plans, the Secretary shall use a systematic interdisciplinary approach
to achieve integrated consideration of physical, biological, economic and
other sciences. [Section 201, FLPMA]
Policy development is rightfully a political
process. When done well it involves defining the issues; gathering the
best scientific knowledge and technology, pertinent facts and opinions
about the issues; and then designing a policy to address the issues in a
scientifically sound, socially acceptable, economically feasible and
legally possible manner. Poor public policy results when scientific
knowledge and facts are ignored, suppressed or distorted to further a
particular political agenda. Likewise, poor public policy can occur when
narrow scientific analysis is used to dictate and justify complex policy
choices that involve social and political outcomes. Both misuses of
science by policy makers and by scientists impact the public’s trust in
BLM’s decisions.
BLM, as defined by FLPMA, is not by itself a
scientific research organization; rather, BLM is a resource management
agency that uses science to inform its land management decisions and
policies. Scientific research provides data and knowledge for BLM
decisions in land use planning, National Environmental Policy Act of 1969
(NEPA) analyses and policy options.
Fundamentally, quality resource management
depends on the interface of science and policy. Within BLM the interface
between science and policy occurs primarily at the field management level
when land management decisions are made or at the national level when
policies are developed. At the present time, the linkage between science
and policy-making is often informal and serendipitous.
Most science providers have rules (policies,
manuals, guidelines, codes of ethics, etc.) for producing science, getting
peer review, and interfacing with policy makers. BLM does not. Thus, BLM
must rely on luck, opportunity and its limited institutional capabilities
to link science and policy.
BLM does not have a separate research
organization. However, it has a wide variety of highly qualified resource
professionals and researchers inside and outside of the agency who provide
scientifically based information to inform the policy-making processes.
Whether science is the underpinning or the
driver of policy is not always clear. Science should be neutral to policy
and both scientists and policy makers need to understand this. Science
provides the facts on which good analysis and policy can be based.
Scientists and policy makers must work together to make decisions on
complex biological, physical and social science issues.
As long as there have been professional
resource managers, there have been scientists in the field of resource
management. Often media reports indicate that those who promote and
oppose BLM policy decisions both use science to justify their policy
positions.
Advancements in policy often lag behind
advancements in science and technology. And, conclusive science is often
not available within practical timeframes to inform management decisions.
Within BLM, the informal linkage of science and policy leads to further
diminishment of science influencing policy. Recent expansion of
concepts such as ecological restoration, landscape scale analysis, and
multiple species habitat conservation plans are just examples. Best
Management Practices based on scientific analysis of their consequences
and efficacy would be an example of an appropriate and timely linkage of
science and policy.
Historical BLM efforts have made a start at
increasing its institutional capability and commitment to the use of
relevant science, but much still remains. On September 26, 2000, the BLM
Director approved BLM’s Science Strategy (available at
www.blm.gov/nstc), which sets forth an overall approach to science
with the following three primary objectives:
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“to delineate the role of
science in BLM decision making and public land management;
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to establish a clear process
for identifying science needs and priorities and to assure that those
needs are reflected in the Bureau’s Strategic Plan and budget; and
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to provide a mechanism for
communicating the Bureau’s science needs, sharing its science and
results, and highlighting its science opportunities on BLM-managed
public lands.”
From the mid-1970s to the mid-1990s, BLM used
a Science Coordination Committee with representatives from each State and
the Headquarters offices to address science needs. This committee played
an important role by providing, among other things, internal coordination
of calls for research priorities from agencies such as the U.S. Geological
Survey, Agricultural Research Service, U.S. Forest Service, etc. The
committee was discontinued for a couple of years (about 1996 to 1998),
re-established in 1998, and then disbanded again within the last few
years. BLM Science Advisor positions in the Headquarters office also were
eliminated. Over time, Science Coordinator positions were created in
several directorates to provide some focus on science at the Headquarters
level. Their success has been directly proportional to priority given to
science by their Assistant Director. And, a commitment by one Assistant
Director did not necessarily translate into a commitment by all Assistant
Directors.
A Science Advisory Board (a Federal Advisory
Committee Act—FACA—committee) was established in about 1996, which
consisted of representatives from outside of BLM. Its charter was allowed
to lapse.
At its annual meeting in Golden, Colorado in
September 2006, PLF was privileged to have Patricia Limerick, Professor of
History, University of Colorado, Boulder, Colorado, as a luncheon
speaker. Professor Limerick spoke about the history of western expansion
and the importance of science to decision-making. Later in the meeting, a
panel composed of a BLM scientist and a BLM manager spoke on “Science in
BLM Decision-making.” Panelists emphasized the need for scientists who
understand BLM laws and programs and can explain their findings in terms
that managers can understand and use in decision-making. BLM panelists
also recognized that the National Science and Technology Center (NSTC) has
limited capability to create new science and that its basic role is
linking field management to relevant science.
As of October 1, 2007, the NSTC became the
National Operations Center Division of Resource Services (NOC-DRS). The
Division supports other BLM offices by providing a broad spectrum of
services in areas such as physical, biological, and social science
assessments; architecture and engineering support; library assistance;
mapping science; photo imaging; geographic information systems
applications; and publications support.
Discussion
BLM’s use of science is part of a continuing
public dialogue. Patricia Limerick has stated: “In shaping the West’s
past, present, and future, no factor is more interesting and consequential
than the role of science.” She goes further to explain a number of
circumstances that reflect BLM’s role, as mandated by FLPMA in the “new
west.” These include such concepts as BLM’s ability to promote
partnerships among diverse interests, skill at advancing ecological
restoration and rehabilitation of degraded habitats, landscape scale
analysis, and skill at adapting to local variation. This management
occurs within a context of multiple risk and multiple demands, commonly
known as multiple use management.
We concur with her conclusions, and proffer
that BLM, as the largest federal land manager with the most diverse land
management responsibilities, has a continuing and expanding role in the
American west to continue its legacy of promoting, utilizing, and
advancing sound science for land management decisions. And, PLF calls
upon BLM to increase its institutional capability and commitment to use
relevant science in policy development, NEPA analyses and land management
decisions.
PLF believes BLM’s Science Strategy clearly
articulates a process for effectively using science and technology in BLM
land management decision-making. However, PLF also believes BLM
management needs to make an even stronger commitment to a) implementing
this Strategy than it has in the recent past, b) acquiring the resources
needed to assure science is given appropriate consideration in natural
resource management decisions, and c) share that commitment with its
staff, constituents and the public. BLM needs to walk the talk.
Numerous BLM land use plans, EISs, EAs and
other projects are protested or litigated, many times on the basis that
BLM failed to use the best science available. As a result, BLM, the
Department of the Interior, and the Department of Justice are spending a
lot of staff time and budget defending plans and projects. To minimize
these drains of time and budget, BLM needs to develop policy and guidance
to ensure that the best science is used in all decision-making. This will
go a long way in defending decisions, if they are challenged.
Practicing science in a political environment
is always challenging, especially without rules and guidelines.
Practicing science in a highly decentralized organization also is
difficult. Current trends in diminishing the role of BLM’s science
organization and eliminating the technology transfer and linkage between
science and policy is troubling. Budget cuts in this arena provide only
short-term benefits and further reduce BLM’s capability to manage the
public lands based on relevant scientific concepts. There are
opportunities for BLM to reinforce its capability and commitment to the
development and use of sound science. We also believe there are
opportunities to further define and refine a linkage between science and
policy. The Forest Service, as an example, has clear roles and
relationships between researchers and policy makers (See Mills, et al).
There are opportunities to formalize roles
and relationships between scientists and policy makers, so that media
misinformation and the loss of public trust can be avoided. Too often,
differences of opinion regarding the amount or adequacy of scientific
information is used as a reason for not proceeding with a decision to
either authorize an action or to deny a request for action. BLM must
protect itself from the manipulation of science by institutionalizing the
linkage between science and policy and strengthening the roles for
scientists, practitioners and managers in policy development.
BLM’s recent Managing for Excellence
initiative, among other things, established a single National Operations
Center (NOC) in Denver, Colorado. This gave the NOC a senior executive to
lead and manage the organization. NOC centralized NSTC (now the Division
of Resource Services), the Lands and Resources Project Office, the
National Information Resources Management Center, the National Human
Resources Management Center, the National Training Center, and the
National Business Center under a single Director who is responsible for
servicing the entire BLM. PLF is on record in support of NOC. PLF
considers it a means of increasing the visibility and stature of the
Division of Resource Services and the other important offices and their
service to the field and Headquarters offices of the Bureau.
BLM should avoid the short-term expediency of
down-sizing the Division of Resource Services. Even under current budget
constraints, it is important that BLM commit to maintaining the current
capability of the Division, and to the role of science and technology in
resource management. A centralized control is needed to ensure that BLM’s
limited research and development dollars are well-spent for the benefit of
BLM as a whole. The Division of Resource Services is the natural location
for this operational work.
The Managing for Excellence initiative should
advance and promote the role of the Division of Resource Services in the
sound development of national policy. This should lead to an advanced
role for the Division of Resource Services to develop scientific analyses
of land management choices, based upon the best available science from
within and outside BLM, with consequences and implications identified for
policy makers to consider.
The BLM is well-served by a modest
centralized science organization like the Division of Resource Services,
lead by a senior executive serving on the BLM leadership team, operated in
cooperation with the entire BLM organization, and supplemented with
various scientific experts who are located at other BLM duty stations.
PLF Position
1. Clear
roles and ethical guidelines need to be established for policy makers and
scientists (i.e., researchers), which foster independent and objective
scientific input into policy formulation. This role statement should be
unique to the BLM multiple use mission (as compared to single use
management) and focus on the complexity of multiple risk assessment in
highly complex habitats and landscapes. The Forest Service’s guidelines
for scientists and managers are an excellent template for BLM to
consider. (See Mills, et al, 2002).
2. Guidelines
need to be established for disclosing scientific consequences that can
guide options and alternatives to be considered in proposed land
management decisions.
3. Increased
commitment to the BLM Science Strategy and to the creation of an
infrastructure to support science and to ensure the best available science
is used in land management decision-making is needed.
4. A
Science Advisory Board should be re-established to provide independent
counsel to the Director on linking policy proposals to relevant and
current science findings, and to discuss the potential consequences of
proposed new policy based on scientific interpolations.
5. The
National Operations Center in Denver should be maintained to strengthen
the linkage of science and resource management decision-making and to
provide increased visibility and stature to the Division of Resource
Services.
Bibliography:
“Making the Most of Science in the
American West: An Experiment,” Patricia Limerick and Claudia Puska,
Report #5, from the Center of the American West, University of Colorado,
2003. Available at
www.centerwest.org
“Achieving Science-Based National Forest
Management Decisions While Maintaining the Capability of the Research and
Development Program,” Thomas J. Mills, Richard V. Smythe, and Hilda
Diaz-Soltero, Pacific Northwest Research Station, April 2002, 20 pages.
“Bureau of Land Management Science
Strategy,” BLM/RS/PL-00/001+1700, Booklet dated September 2, 2008.
Click here to access.
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Updated from PLF No. 31-07, dated May 1, 2007 |