Analysis Paralysis-Gridlock Redux- Who’s Responsible?

“Forest planning has been hijacked by a generation of planners who turned what should have been a narrowly-focused effort to constrain an out-of-control Forest Service logging program and turned it into a wasteful, endless, bureaucratic exercise with little merit. “ Andy Stahl (my bolding)

My memory was the that FS had identified overanalysis as a more general problem and had looked internally and externally to describe the sources and some solutions. NOTE: that this was more focused around project planning than forest planning, but one might hypothesize that some of the causes and cures would be the same.

I do remember some thinking going along the lines of : if people don’t want projects or plans to happen, and they appeal and litigate on procedural grounds (NEPA and NFMA processes), then the FS needs to develop “bullet proof ” documents.  This is a dynamic  which inexorably leads to over-analysis.

Some empirical evidence might be looking at other agencies and seeing how much they over-analyze (given that the right level of analysis is in the eye of the beholder) and attempting to correlate that with amount of litigation. I did have some experience with some APHIS NEPA that would suggest that since at the time they faced  little litigation, they did not over-analyze.

I was looking for the original FS report on gridlock, and ran across a couple of interesting things in my internet search.

One is a discussion between Neal Sampson and Andy Stahl about gridlock in 1995.

I also found the original report on Process Predicament from 2002. From the Executive Summary on page 5 :

Unfortunately, the Forest Service operates within a statutory, regulatory, and administrative framework that has kept the agency from effectively addressing rapid declines in forest health. This same framework impedes nearly every other aspect of multiple-use management as well. Three problem areas stand out:

1. Excessive analysis—confusion, delays, costs, and risk management associated with the required consultations and studies;

2. Ineffective public involvement—procedural requirements that create disincentives to collaboration in national forest management; and

3. Management inefficiencies—poor planning and decision-making, a deteriorating skills base, and inflexible funding rules, problems that are compounded by the sheer volume of the required paperwork and the associated proliferation of opportunities to misinterpret or misapply required procedures.
            These factors frequently place line officers in a costly procedural quagmire, where a single project can take years to move forward and where planning costs alone can exceed $1 million. Even noncontroversial projects often proceed at a snail’s pace


Finally I found a news report in which both Chris Wood and Mark Rey panned the above report. Now, usually Chris Wood and Mark Rey tend not to be on the same side, at least on things that are politically charged,  so the fact that they neither thought much of the Process Predicament report is somewhat intriguing.

It sounds like we (the combination of externals and internals) never really worked through this issue, and it remains unresolved.   Re-investigating the causes and cures for this phenomenon, or at least how it applies to forest planning,  may be important to design plans with appropriate levels of analysis and planning rules to require an appropriate level.

7 thoughts on “Analysis Paralysis-Gridlock Redux- Who’s Responsible?”

  1. Sharon,

    If we once again have this debate about efficiency and the process predicament, I hope we’ll consider the following quote by the GAO. It is as relevant today as it was in 1997:

    “Strengthening accountability for performance within the Forest Service and improving the efficiency and effectiveness of its decision-making is contingent on establishing long-term strategic goals that are based on clearly defined mission priorities. However, agreement does not exist on the agency’s long-term strategic goals. This lack of agreement is the result of a more fundamental disagreement, both inside and outside the Forest Service, over which uses the agency is to emphasize under its broad multiple-use and sustained-yield mandate and how best to ensure the long-term sustainability of these uses.”

    GAO, Forest Service Decision-Making: A Framework for Improving Performance (GAO/RCED-97-71, Apr. 1997), 5.

    I’m of the opinion that the statutory framework of the USFS needs a comprehensive review and reevaluation and (with Jim Burchfield) have made some unsuccessful pushes in that regard.

    When it comes to efficiencies, the GAO report may help us appreciate the limits of what can be done via planning regulations.

  2. I like your observations, Sharon, on the level of analysis being in the eye of the beholder and the sense that an agency, like APHIS, only starts overanalyzing once it gets litigated. But what is it that creates this defensiveness that an agency develops to force over-analysis? Is it a defense of a favored proposal? A worldview that advocates certain practices? Why be defensive and inefficient in the first place? Why not turn it all on its head an ENCOURAGE appeals. Produce an efficient analysis and recognize that it might need more detail. Ask what that detail might be, and then you could avoid all the wasted energy on issues that really don’t matter all that much.

  3. Martin- Professor Mark Squillace of the University of Colorado Law School has suggested a new Public Land Law Review Commission. That makes more sense to me as I have some experience with ServiceFirst (BLM and the FS working together as one unit) (even currently working on a forest plan and an RMP as one effort at the San Juan Public Lands Center!). There are so many opportunities for improving public service across public land boundaries- it’s fairly unimaginable to those not involved- with taking the best of each agency’s approach. I think some of the major leaders toward the 21st Century Public Service are those ServiceFirst employees who keep their eyes on the prize of public service while the sheepdogs of bureaucracy keep nipping their heels (OK, not the best analogy).

    Jim- I like your ideas but think that there is some kind of tendency already to simplify if we know there are no deeply held issues nor potential litigants.

    One example would be, we have certain folks who appeal many of our grazing permit renewal decisions. It is kind of coevolutionary with us and them; they perceive holes in our documents, we beef them up, they perceive new holes, etc. Fundamentally they would be happy if we didn’t have grazing at all, and have access to legal counsel so.. is there a way to break out of the cycle, or is the cycle simply part of doing business in our regulatory/legal system?

    And sometimes I wonder whether all our creativity and time spent on extra documentation, litigation and appeals, and the conservation community’s time and creativity spent on documentation litigation and appeals, and the carbon and paper for all those documents.. if we just used the creativity and put the time and funds into conservation easements for wildlife corridors instead, would the environment be a better place? Oh well.

    As a natural resource person, I actually prefer the objection to the appeal process as that is more concerned about what we might do differently, than what we might document differently.

    • Sharon,

      I’m glad to hear that Professor Squillace has come to this conclusion about another commission as well. It seems that an increasing number of influential folks are recognizing some of the underlying statutory issues that need a careful revisitation.

      A couple years ago Senator Jon Tester asked Jim Burchfield and myself to address selected problems and issues pertaining to National Forest management. Our most important recommendation—and the one that has really gone nowhere yet—is a call for a comprehensive review of National Forest law and management. The Report is available at

      and that recommendation begins on p. 22.

      At some point I hope we can generate a more inclusive discussion about this idea, especially as it pertains to yet another round of forest planning regulations.

      Consider, for example, the controversy surrounding the recommendations that were made in the last Committee of Scientists Report, with at least one COS member feeling as though the Committee overstepped its bounds. See Roger Sedjo, “Mission Impossible,” Journal of Forestry 97, no. 5 (1999), pp. 13-14. I don’t necessarily see it this way, but it does tell us something about the limits of reform via planning regulations

  4. Thanks Sharon. We most certainly did not work through the analysis paralysis/process gridlock question. But we were, of course, sidetracked by Bush Wars and domestic paranoia that came with the Cheney/Bush Administration post 9/11. Remember that things were so bad in the FS at the time that analysis paralysis/process gridlock was eventually wordsmithed into the “process predicament”just before it slipped quietly below the surface of polite conversation in the Forest Service.

    Here is a link to my little process gridlock suggestion at the time (2003):

    And here is a tidbit of what I offered up back then:

    We need to learn to distinguish between ‘managing the expected’ and ‘managing the unexpected.’ We need to recognize that usually both are at work at the same time: While managing the expected, expect to be surprised! We need to learn to embrace a world filled with surprise and quit trying to force the unexpected into organizational frames (rules, regulations, etc.) suited for the expected. (See: Managing the Unexpected, Karl E. Weick and Kathleen M. Sutcliffe) We need to quit trying to tame politically wicked problems. Instead we should recognize them for what they are and deal with them in all their wildness.

    • Dave- thanks so much for rejoining the discussion.. “Forest Policy Forest Practice” was something Martin and I remembered as a great forum that somehow we needed to continue.

      It would help if you could make your suggestions a bit more specific; for example, if we are managing the unexpected, how would that change our approach to analysis paralysis? Most of us don’t have time to read the primary sources. Since you have, it would be great if you would convert those ideas into more concrete suggestions. It’s great to have you back!

  5. Sharon,

    I don’t want to get “into the weeds” with specifics, since I think that the Forest Service has over-complicated everything with specifics built into manuals and handbooks that fill rooms.

    On the phone with Martin just now I mentioned that if I could get Chief Tidwell’s ear I would suggest a means to get out of process gridlock hell: Find a savvy planning director for the agency who would shepherd development of a very simple planning rule that would embrace scenario planning to set a stage for adaptive management. Then begin to re-culture FS managers top to bottom to become able adaptive managers, following principles and practices advocated by W. Edwards Deming and his various disciples.

    I remember learning/discussing Adaptive Management with Lance Gunderson and Steve Light (now members of the Resilience Alliance) many years ago at a FS session in Albuquerque. Gunderson and Light’s advice was then, and is no doubt still now very simple: wade in and begin!

    The Forest Service’s problem is that the agency bureaucracy simply doesn’t trust it’s practitioners enough to practice adaptive management as it is meant to be practiced. The agency still wants to control it’s practitioners tightly. It is still searching for a “directives solution” to wicked political problems. It is a fools’ quest.


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