Agency Efficiencies

Forest Service to revise NEPA procedures

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The Forest Service is proposing to revise its NEPA procedures (including its regulations at 36 CFR part 220, Forest Service Manual 1950, and Forest Service Handbook 1909.15) with the goal of increasing efficiency of environmental analysis. The Forest Service’s NEPA procedures were last reviewed in 2008 when the Agency moved a subset of its NEPA procedures from the Forest Service Manual and Handbook to the Code of Federal Regulations. However, the Agency’s NEPA procedures still reflect in part the policies and practices established by the Agency’s 1992 NEPA Manual and Handbook.

The Agency is seeking public comment on the following:

  • Processes and analysis requirements that can be modified, reduced, or eliminated in order to reduce time and cost while maintaining science-based, high-quality analysis; public involvement; and honoring agency stewardship responsibilities.
  • Approaches to landscape-scale analysis and decision making under NEPA that facilitate restoration of National Forest System lands.
  • Classes of actions that are unlikely, either individually or cumulatively, to have significant impacts and therefore should be categorically excluded from NEPA’s environmental assessment and environmental impact statement requirements, such as integrated restoration projects; special use authorizations; and activities to maintain and manage Agency sites (including recreation sites), facilities, and associated infrastructure.
  • Ways the Agency might expand and enhance coordination of environmental review and authorization decisions with other Federal agencies, as well as State, Tribal, or local environmental reviews.

Bigger projects, more categorical exclusions, shorter timelines, but “The Agency will continue to hold true to its commitment to deliver scientifically based, high-quality analysis to decision makers that honors its environmental stewardship responsibilities while maintaining robust public participation.”

Review of collaborative restoration initiatives

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The Forest Service funded a study (2 page summary here) of the Collaborative Forest Landscape Restoration Program and the Joint Chiefs Landscape Restoration Partnership.  Of note (to me any way):

Findings:  “Strong majorities said they had increased the pace and scale of restoration, improved ecological conditions, and reduced the threat of fire to communities.”  “61% said they had decreased litigation.”

Implications:  “The agencies should continue to make changes to their business model to ensure that their organizations are oriented towards the success of priority projects. The agencies should ensure quality leaders and staff capacity follow priority investments. The agencies also could refine proposal evaluation processes to better identify places likely to be successful, or those that are in need of support and capacity building.”

(I assume that the project “priorities” are a result of collaboration, too.)

Plan for logging in Daniel Boone National Forest threatens rare flowers

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This is about a formal objection to a logging project.  I think it illustrates one of the major issues we see in a lot of conflicts about logging (and an eastern example to boot):  what role should timber sale economics play in project selection and decision-making?

From the objectors:

Instead of focusing restoration efforts where they’re most needed, the Forest Service is going where the timber is,” Scheff said.  Scheff said there is a genuine need for appropriate measures to improve the health of the area, which is home to unusual or rare features including sandstone glades, Appalachian seeps and spots of native grassland. But the Forest Service could use methods other than commercial logging at many sites to achieve the goals of the project, Scheff said.

From the Forest Service:

The Forest Service said logging as part of the Greenwood project would help the local economy.  Reed said commercial logging is a tool to help improve the national forest, bringing in money for work the Forest Service would otherwise have to pay to get done.  “It’s an efficiency and it’s common sense,” Reed said.

I at least hope the NEPA process clearly laid out the differences in effects between these alternatives, and the reasons for the choices made.

Enjoined timber sale “renegotiated”

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The Johnson Bar Salvage Sale on the Nez Perce-Clearwater National Forest has been approved by the Forest Service and the litigants.  (Johnson Bar has been previously discussed here in several posts.)

Following the injunction, Nez Perce-Clearwater National Forest Supervisor Cheryl Probert pulled the project and committed to a rewrite that was completed earlier this year. The environmental groups filed objections to the new logging plan, but those objections were resolved through negotiations between the agency, the environmental groups and timber companies.

“Nobody got 100 percent of what they wanted in this effort. But they have been really good about working through the process and understanding it’s in all of our best interests to get something done out there,” Probert said.

Bill Higgins of the Idaho Forest Group — one of the timber companies that successfully bid on the sale — estimated it will produce 25 percent to 40 percent of the original volume

“It’s not the best outcome,” he said. “The original project implementation on the schedule they were on was the desired outcome. This is making the best of kind of a bad situation.”

The project eliminates logging in areas that are visible from the river and places the groups feared were prone to erosion and landslides or areas that could degrade steelhead spawning habitat.

What’s not to like about this?  Maybe only that they could have done this without the litigation step, but apparently the litigation step was needed to convince the Forest Service that it couldn’t just do what it wanted without a fight.  (Anticipating Sharon’s argument, let’s assume that the timber purchasers and local governments were not formally “at the table,” but they were free to advise the Forest Service on what they wanted.)

Humans sparked 84 percent of US wildfires, increased fire season over two decades

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How should we deal with the new math on forest fires?

If this article published in the February Proceedings of the National Academy of Sciences is not a fluke then it would seem to me that our expanding population dictates the need for more forest management not less. The less desireable alternative would be to severely restrict access to our federal forests. The main conclusion of the article is that humans sparked 84 percent of US wildfires and caused nearly half of the acreage lost to wildfire. This number excludes intentionally set controlled burns.

From the above, I would deduce that human initiated fires caused proportionally less acreage loss because they were closer to civilization and to forest access points and therefore closer to and more easily accessed by suppression resources. The fact that nearly half of the wildfire acres lost occur in these areas suggests that we would get more bang for our tax dollars if we increased and focused federal sustainable forest management around high traffic areas easily accessible to humans.

Knowing that humans who cause wildfires are, by definition, either careless or malicious, we might deduce that they are generally not inclined to put great effort into getting to their ignition set points. This would lead us to consider that human caused fires might prove to be in less difficult terrain areas with high human traffic. Fires like the Rim fire being the exception. That, if true, would suggest that forest management for risk reduction on these sites could be done at lower costs per acre than other less accessible forest acreage. Focusing forest management efforts on these high benefit to cost areas would have the biggest bang per tax dollar expended in order to lower the total cost of federal wildfire control. If my thinking is correct, this should play a large part in setting the priorities as to where we should: 1) apply controlled burns to reduce ground and other low fuels, 2) utilize commercial thinnings to reduce ladder and proximity fuels or 3) use commercial regeneration harvests to create greater variation in tree heights between stands in order to provide fire breaks for crown fires when appropriate for the site and species. The net effect would be positive for all species including endangered and threatened species. There would still be plenty of lightning caused wildfire, controlled burn hotspots/breakouts and a significantly reduced acreage of human caused fires to satisfy those who don’t mind national ashtrays. Reducing the number and size of human caused fires would also free resources to attack lightning fires earlier and harder when allowing the fire to burn was not an option.

Pertinent Quotes:

  1. “After analyzing two decades’ worth of U.S. government agency wildfire records spanning 1992-2012, the researchers found that human-ignited wildfires accounted for 84 percent of all wildfires, tripling the length of the average fire season and accounting for nearly half of the total acreage burned.” Italics added
  2. “”These findings do not discount the ongoing role of climate change, but instead suggest we should be most concerned about where it overlaps with human impact,” said Balch. “Climate change is making our fields, forests and grasslands drier and hotter for longer periods, creating a greater window of opportunity for human-related ignitions to start wildfires.”” Italics added
  3. “”Not all fire is bad, but humans are intentionally and unintentionally adding ignitions to the landscape in areas and seasons when natural ignitions are sparse,” … “We can’t easily control how dry fuels get, or lightning, but we do have some control over human started ignitions.””

Forest planning could promote efficiency by “standard work”

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The Colorado Department of Transportation and U. S. Fish and Wildlife Service have developed a new process for protecting federally listed species. “When fully implemented, the improvements made through SWIFT will also save CDOT hundreds of hours of report writing and tens of thousands of dollars of consulting fees every year.”

“SWIFT is a programmatic statewide review that assesses impacts to these protected federal species and implements pre-determined standardized conservation measures to avoid or minimize impacts to the species and associated habitat – a great example of using the Lean principle of “standard work”. SWIFT provides these standardized impact assessments and mitigation measures for 92 common CDOT construction activities for all threatened or endangered species in the state as well as candidates for future listings. SWIFT is a tool to expedite project delivery by providing project teams with consistent impact determinations for similar work and predictable conservation measures.”  (“Lean” is a management principle that means creating more value for customers using fewer resources.)

The Forest Service has completed similar programmatic consultations on land management activities that may affect listed species. The result is to streamline consultation on projects that fit the pre-determined conditions.   However, individual managers can choose not to follow them and incur higher consultation costs.  Forest planning should consider the costa and benefits of allowing this discretion, and consider incorporating plan components that promote standardization of conservation measures for projects in the plan area.

The Forest Service has also worked with the consulting agencies to adopt uniform conservation and mitigation measures across the range of certain species in its forest plans (such as for Canada lynx). However, in general, the Forest Service resists the idea of adopting “standard work” principles in its forest plans, preferring to characterize this in derogatory terms as “one size fits all.”   It seems to prefer to allow local managers to invent their own wheels, as indicated by proposing changes in range-wide conservation strategies during individual plan revisions, and avoiding the use of mandatory standards that all projects would have to comply with.

Most managers (like those with CDOT) would recognize this as a costly and inefficient process. What does it buy? Comparing the costs and benefits of Forest Service decentralized decision-making would be a good exercise for the GAO on behalf of federal taxpayers.

 

Do we need national ‘forests?’

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Things seem a little quiet out there, so here is my response to Sharon’s asking what I  think about “disappearing districts” on June 12.  The problem I see with the approach of consolidating districts (and national forests) is that is an ad hoc and opportunistic response, and I haven’t seen much of an effort at long-term strategic planning for what the current and future agency should look like.

I think there are some good arguments for maintaining a local ‘face’ of the Forest Service responsible for implementing policies and programs.  I think that could be done with many staff specialists located elsewhere and in different places.  Something close to a “one person ranger district” might make sense again.

On the other hand, what purpose do national forest administrative units serve?  There is a need for someone at a higher level and with a broader view to develop policies and programs.  But is there really a need for a hundred-and-how-many different sets of policies?  There is a historic and legislative basis for national forest boundaries, but I think that the decentralization of authority that has been tied to that works hard against the need to reduce government costs (as well as creating artificial cross-jurisdictional management problems).

 

I think that the Clinton Administration had the right idea that the Forest Service can’t afford four layers of bureaucracy.  What would happen if we eliminated national forest supervisor offices?  Or if that’s too many districts for a regional office to handle, a more reasonable alternative might be to reorganize based on states or multi-state units (like the BLM, which would make it easier to eventually merge with the BLM).  This might even improve working relationships with the states.

 

 

End of an Era?

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It’s not a surprise that the Forest Service is hiding their response to the sequestration. Simply put, modern projects treat more acres and cut numerous small trees. They cannot accomplish this work without temporary employees. My last year’s Ranger District currently has TWO permanent timber employees, and two others shared with another (larger) Ranger District. I wonder if our Collaborative funds will be returned to the Treasury if projects aren’t completed.

I guess the only way to find out how bad it will be is to welcome the collapse, then decide how to fix it. Meanwhile, the best of the temporaries will find careers (or jobs) elsewhere, and they won’t be coming back. It is hard enough to live on just 6 months of work, each year.

When Policy Trends Toward Bullshit

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Much government policy and some law resides in a realm philosopher Henry Frankfurt labels “bullshit”—in earlier times called humbug or balderdash. Much US Forest Service policy falls here too: regulation, manual and handbook directives. At least that’s the way I’ve seen it for a very long time.

Early in my Forest Service career, a colleague and I were conscripted into a week-long Forest Service Manual/Handbook writing exercise, specifically focused on the Forest Planning sections. A quick survey of the materials led us to conclude that our week had to be spent making sure that there was nothing in the FS planning manual that could possibly harm anyone. We knew that we could not ‘fix’ the manual, so we spent our week in a second-best endeavor.

A few years later a FS Planning Director asked a group of us for policy ideas at an economists conference. I suggested a bold move: Throw the Forest Service Manual and Handbook in the Potomac. I made the recommendation in the main because both the FS Planning and Economics Manual/Handbook materials were pretty much bullshit. Note that I immediately added that people should be able to swim out and retrieve portions of the policy manuals they deemed useful, and then upgrade them as necessary to help advise program development, project design and work generally. The point was to decommission the whole mess, and free the agency of both the manuals/handbooks and the mini-bureaucracy that oversaw them. Of course I didn’t believe that the FS would act on my suggestion, at least not then. But one can always hope. [Note: I wish there were electronic copies of earlier FS Manual/Handbook materials to point to for historical (hysterical?) purposes. ]

I suggested “tossing” the FS manual and handbook to both Chief Dombeck (via Chris Wood) and Chief Bosworth. Both were somewhat warm to the idea, but nothing happened. I’ve once again raised that issue with FS top brass, suggesting that collaborative adaptive governance can’t work if everybody shows up with several yards worth of “holy writ” that must be followed.

Later I called bullshit on the Forest Service’s initiative to tie planning (and pretty much all else) to environmental management systems—chronicled in my Forest Environmental Management Systems blog (Oct. 2005 – April 2007). That particular mess went away, with EMS rightfully retreating to a minor place (facilities and fleet management) in Forest Service administration. I’m sure my blogging did not influence the outcome. But at least I left a record, so that we might learn from the mistake.

Common wisdom says, “When you find yourself in a hole, stop digging.” Let’s pause a moment and explore special characteristics of what we are digging through.

What is ‘bullshit’?
Before anyone gets too upset with my BS terminology, maybe we ought to delve into Frankfurt’s little book On Bullshit—an essay really, which you can read online. Frankfurt’s little book adorned a special shelf in my FS office bookshelves, accompanied by Joseph Heller’s Catch-22 and Something Happened, Lewis Carroll’s Alice in Wonderland, and some other classics. Frankfurt begins On Bullshit with,

One of the most salient features of our culture is that there is so much bullshit. Everyone knows this. Each of us contributes his share. But we tend to take the situation for granted. … In consequence we have no clear understanding of what bullshit is, why there is so much of it, or what functions it serves.

Frankfurt attempts to tease out a ‘theory of bullshit’ for us. I’ll not bore you with all Frankfurt’s building blocks, but I at least we need to know that he distinguishes bullshit from lying, in part as follows:

The essence of bullshit is not that it is false, but that it is phony. … The bullshitter is faking things. But this does not mean that he necessarily gets them wrong. [But it does mean that they don’t quite ring true.]

How much FS policy falls in this realm? Politicians tend to create bullshit to pander—to curry favor. Bureaucrats create bullshit for very different reasons. Frankfurt says,

Bullshit is unavoidable when circumstances require someone to talk without knowing what he is talking about. … [This is] common in public life, where people are frequently impelled—whether by their own propensities or by the demands of others—to speak extensively about matters of which they are to some degree ignorant.

Think about how Forest Service teams are put together, often without asking for volunteers and without too much regard for seeking out the most knowledgeable team members. It always seemed to my jaundiced eye that team members were selected to construct manual and handbook materials in the main because they were ‘good soldiers’, and particularly not ‘radicals’ who might rock the boat too much.

Why I’ve tried to stop the BS

I know that it is pretty much a fool’s quest, but I’ve always tried to get the Forest Service bureaucracy to ‘swing for the fences’ and pull itself up from the morass of its own policy, manuals and handbooks. But, like many American institutions the Forest Service will not take a hard look at itself. Maybe it’s due of fear. Maybe it is due to ennui—stuckness, lack of hope. Maybe it is something else. Maybe it is just because they don’t realize that bullshit might be outright harmful, even toxic to the organization.

This proves especially true when bullshit policy is brought into court, “for the record,” when people challenge federal actions, which must be based on federal policy. At the point federal policy bullshit makes an appearance in court, federal judges are not pleased to have to wade through it—so we too often get strongly-worded federal decisions against the Forest Service.

In any case, meaningful links between process and outcome in the Forest Service often simply don’t exist in any practical sense. They are too encumbered by bullshit. For example, we often hear that if the Forest Service can’t fix the Forest Planning process (for example) in ‘rulemaking’ then we’ll fix it in forest plan implementation—as if that can happen. Isn’t such talk just administrative governance denial?

I keep the pressure on, hoping against fate that a miracle will occur, as it did with General Electric not too long ago, just before GE was to fall in to a bureaucratic quagmire from which it would not, could not escape. Make no mistake, the GE rebirth was brutal. But the company is arguably much better today than before—now that fierce conversations are standard practice innovation is center stage, and people are required to challenge each other to do better, and to be better. Maybe someday the same will happen in a government agency, even perchance to the Forest Service. But I’m not holding my breath.