QLG Member
Comments on the paper entitled
"The Quincy Library Group and Collaborative Planning
within U.S. National Forests"
by Charles King and M. Dawn King's
John Sheehan and George Terhune commented on Charles King and M. Dawn King's paper on the QLG. Their comments are provided below.
Charles Davis and M.Dawn King.
I enjoyed your recent piece on QLG. You may receive comments from other QLGers and here are mine.
First: Hie thee to the website (www.qlg.org) and you can get some of the fulsomeness you're seeking.
Second, we at QLG don't normally make proposals to undertake specific projects to USFS. I don't think any of us consider QLG to have risen to the status of 'Junior Partners' or 'satutorily mandated power sharing', but something quite less. As soon as they come up with a project area and some idea of the scope of work, we do talk with them (in fact, we're always chatting them up to distraction) and sometimes go out and view the projects (at publicly noticed tours) and make suggestions (without any veto power, actual or implied).
USFS finished their mandated programmatic EIS (on 8/99) for the entire five year project and basically adopted an alternative that reflected the Act. The forest service activities (especially in vegetation management) for the next five years will be "QLG" type activities authorized in the Act and defined more specifically (mapped) in the EIS. They've started the process of developing priorities for those thinning projects and a pretty firm plan of action for this FY (thru 9/00) and some"out year" priorities. They are USFS priorities within their read of the Act. We comment on the individual projects (say1,000 acres of thinning) and really gripe if they start faltering on the pace and scale of the program, but we don't initiate the projects or have any formal authority over them beyond that accorded any other citizen under the standard NEPA review that accompanies each individual project.
We do help initiate (and find money for) stream restoration activities on USFS lands ($3.5mm of outside money on USFS lands in the area since the Act was passed) under other authorities.
Finally, We never made a decision to "bar outside groups from our regular meetings" (p.11). We did vote (after some discussion) to allow our main working committee on implementation of the Act (P2C2 or Plot Project Consultation Committee) to have executive or closed sessions as part of their irregular meetings. The monthly QLG meetings are publicized, fully open and well attended and go on and on and on... You ought to come some time and spend the day in our library.
John Sheehan
"Congress shall pass no law that abridges the rights of citizens to petition their government for a redress of their grievances."
Professor Davis,
John Sheehan sent me a copy of his comments on your QLG article, so I won't repeat all the points he made, except where I think a more complete explanation might be helpful. I also want to offer some additional comments on points that he perhaps didn't cover. I reformatted your text to remove the extra line spaces, so I can't refer to passages by page number and paragraph, but I will try to cite enough context to make the references clear.
John mentioned the inaccuracy of calling this "statutorily mandated power sharing," and I would add to his list such passages as "collaborative decision-making," "shared decision-making authority," "it allows participants to develop projects that the Forest Service is obliged to accept if the proposed activities can be accommodated within the existing plan without violating existing laws or regulations," "shared governance," and "[QLG] as a private group that has been delegated a form of public authority." In fact none of these statements is true, and failure to correct the underlying misconception would completely undermine the legitimacy of any references to QLG in the policy debate you implicitly recommend.
I believe the problem stems from your uncritical acceptance of the terms "collaboration" and "local control." We're painfully aware that other people have applied those terms to the QLG proposal and the HFQLG Act well before you did, some of them innocently and some of them for purposes of intentional misrepresentation. I also admit that we have been unable to secure corrections as fast as the mistakes have been published. Nevertheless, I think a proper critical reading of the source papers (the QLG Community Stability Proposal and the HFQLG Forest Recovery Act) would provide NO evidence that QLG sought or was given any decision-making authority. Neither does QLG "collaborate" with the Forest Service in any normal sense of the word, and certainly not in the special sense the Forest Service defines as collaboration with non-federal entities. According to your own article the Forest Service first decided it would somehow be illegal to attend QLG meetings, which surely is not the stance of a "collaborator." They subsequently abandoned their mistaken idea, and now some FS officials attend most meetings to observe and answer questions. However, neither the FS as an institution nor any FS employee is a member, and QLG is not a member of any FS-sponsored "collaboration." While we try to maintain cordial working relationships with individual FS employees, if you ask any local FS official you will probably be told that the institutional relationship is at least arms length and usually someplace between antagonistic and hostile. Very likely the last thing they would call it is "collaboration" in either the official or the common sense meaning of the word.
Just to pin down this point, because I think it is extremely important, please refer again to the paper you listed that my wife and I presented at a workshop in West Virginia during October 1998 (your footnote #19). About half way through the paper, under the sub-head "Preparing to Implement the Pilot Project," is this paragraph:
"In passing the QLG bill, Congress gives no special power or management role to QLG. Instead, the bill contains direct orders, from Congress to the Forest Service, to accomplish a specific list of tasks in a five-year Pilot Project and report on what it has accomplished. QLG will make suggestions and offer comments on the Pilot Project EIS, and perhaps on individual projects, on the same basis as anybody else who cares to comment, but has no other role in the Forest Service management decisions."
I'm not sure how we could say it more clearly, though God knows we've tried and not been too successful.
The QLG Community Stability Proposal is clearly labeled just that: a "proposal," and in the document it is also called a "suggestion."
In the Act itself there are only two mentions of an on-going QLG role: Subsection 2-(h) "Consultation. -- (1) The statement required by subsection (b)(1) [the EIS] shall be prepared in consultation with interested members of the public, including the Quincy Library Group;" and Subsection 2-(k) "Final Report ... (2) Preparation ... The panel shall prepare the report in consultation with interested members of the public, including the Quincy Library Group." I don't see how "in consultation with interested members of the public, including the QLG" can fairly be described as local control, shared decision-making, delegation of public authority, a process that directly binds policymaking, or a power-sharing arrangement.
The reason John Sheehan quoted (well, slightly mis-quoted) the First Amendment is that we view our action in approaching Congress as an exercise of the right peaceably to assemble and petition for redress of grievances. In fact, during our first trip to DC, we literally presented a petition signed by about 2,500 local residents, which I think ended up, somewhat ironically, in the office of our erstwhile champion, Senator Boxer.
Well, I've beat that one to death, so I'll taper off with just three technical errors under your sub-head "The QLG Plan" that are much less important, but you might want to correct them if the occasion arises.
1. The mapped acreages and the labels that go with them. These have given everybody trouble, and even the Forest Service can come up with different numbers for its land-holdings on different occasions. The Act refers to a QLG-generated map that divides Forest Service land in the affected area, about 2.3 million acres, into three categories: Off-base, Deferred, and Available for Group Selection. In effect the Act prohibits management activities that involves timber harvest or road-building anywhere in the Off-base and Deferred areas during the term of the Pilot Project. Those two categories, along with areas already designated wilderness or in other prohibited status, total about 700,000 acres. This leaves about 1.6 million acres labeled Available for Group Selection. That label is perhaps unfortunate, because other management is permitted, and in fact required, not just group selection. The fuelbreaks, the group selection, and any individual tree selection that is done under the Act must occur in that 1.6 million acres during the Pilot Project. Therefore it is not accurate to say "...fuelbreaks on 40,000 to 60,000 acres a year within the 2.25 million acres," unless you want to carry logic to a misleading extreme by saying that the 1.6 million acres it also nested within the 2.25 million. (That's the kind of argument I might occasionally make in a "discussion" with my wife, but surely you wouldn't try it.)
2. In that same section you say "...group selection on a little more than half the project area annually..." At first I couldn't imagine where that number came from, but then realized that you saw 0.57 of project area, when the Act actually says 0.57 percent of the project area. The computation is simply 0.0057 x 1.6 million = approx 9,300 acres. (In the EIS the FS made additional adjustments to their landbase calculations and came up with about 8,700 acres.)
3. Finally, the Act does NOT include the Sustained Yield Unit that was recommended in the original QLG Community Stability Proposal. Almost immediately after it was recommended the Forest Service decided the SYU was a dead issue, so it did not survive to become part of the HFQLG Act.
I hope you don't mind my being so direct and specific about what I see as errors of fact in your paper. I intend to be helpful, though no doubt my motive is mainly to help QLG first, and you only second. If it's any consolation, you ought to see how pointed the comments and heated the arguments can get in a QLG meeting. And we all think of ourselves as close friends by now.
Thank you for sharing your paper with us,
George Terhune