EADM- Process Predicament Redux?

Andy Stahl reminded me of the Forest Service’s previous work on Process Predicament. It’s a 40 page paper, and it is interesting to reflect on what has changed and what hasn’t in the last 16 years. Here’s what they said in 2002:

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.

Forest Service officials have estimated that planning and assessment consume 40 percent of total direct work at the national forest level. That would represent an expenditure of more than $250 million per year. Although some planning is obviously necessary, Forest Service officials have estimated that improving administrative procedures could shift up to $100 million a year from unnecessary planning to actual project work to restore ecosystems and deliver services on the ground.


It is time to tailor the Forest Service’s statutory, regulatory, and administrative framework to the new era of public land management. Part of the solution will be internal. However, the problem goes far beyond the range of control of any single agency, or a single branch of the government.
The Forest Service will need to work with partners, both in and out of government, to establish a modern management framework. By working together with partners to create and operate within such a framework, the Forest Service can focus more of its resources on responsible stewardship and thereby improve public trust and confidence in the agency’s ability to care for the land and serve people.

Some of the efforts to improve NEPA included more contracting, better IT support for applications and a variety of other things (many of which our blog regulars were involved with). It sounds like EADM is covering some of the same territory. I’d be interested in the views of others on 1) what has been improved in this time period, and 2) what challenges remain.

15 thoughts on “EADM- Process Predicament Redux?”

  1. In addition to the Process Predicament work that is part of this history, there are several Dialogos reports that look at USFS decision making, especially in the wildland fire community. Those have had a meaningful effect as far as I know, but I’d defer to current wildland fire professionals. I know I found the material useful and substantive when I was with the agency, especially as an acting Forest Supervisor and acting Natural Resource Staff Officer, both during a period when the agency was looking at what was called the “Safety Journey.” Some of this material is still available through WildlandFire.com, but the site appears to have been shuttered and no longer maintained.
    Original Dialogos report: http://forestpolicy.typepad.com/am/dialogos_report_fs_nlt_v8_5.pdf
    Dialogos follow-up report/memo:http://www.wildlandfire.com/docs/2008/fed/dialogos-followup-report.pdf

      • Hey, Dave, I did some legwork on this today and what I find is confusing.

        Yes, looking back, these Dialogos reports were the basis for the Safety Journey, which was a multi-year investment in improving the safety practices of the agency, at least related to fire. I and others saw it at the time as an opportunity to improve the organization more broadly through attention to improved decision practices, application of practices for capturing and sharing lessons-learned, and for avoiding various cultural decision traps identified in the Dialogos work.

        What I see today, however, is odd because my internet search for “USFS safety journey” found little recent and nothing active, at least on the public facing USFS web presence. I also saw a competing set of USFS webpages. First, there’s a set of what appear to be live, actively maintained, yet largely superficial pages with a nice looking and roughly standard template. But, there’s also a set of still useful, yet ghost pages with a dated template and great, yet dusty content. Each set of pages seems less than worthwhile.

        I’d have to defer to those still in the agency for a better answer to your question.

  2. thanks for digging up the Process Predicament! I was wondering if there were some similarities. I don’t know if I ever read or knew about the report. I think the public involvement part of the process predicament is not an issue anymore because of all of the collaborative work. but I don’t think we ever made much progress on the other 2 items. And one thing that is in EADM that is not in PP is that some of the overanalysis is because we are not using the environmental effects from implementing other similar projects in the past to improve our ability to reduce analysis in the future.

    The Safety Journey is apparently still going, but I never really cared for it. And I haven’t seen any measures of how effective it is/was. Since that hasn’t been very apparent, it makes me wonder if anything has improved. In the few serious accidents that I have seen since SJ started, there seems to be more of a “blame the victim” approach afterwards instead of an institutional “lessons learned” approach. but perhaps that was just the forest that I was on.

    As one of my old bosses said, once something starts, you’ve got 2-3 years to make some headway before the energy behind it disappears or is replaced by something else.

  3. The way I remember this was that it was in part a reaction to the 2000 Clinton Planning Rule by the new Administration, which they never let go into effect. The 2012 Planning Rule now in effect should have resolved those questions (“resolved” as in provided an answer; not necessarily fixing the problem). One specific point involved analysis of species viability for every project. That requirement was eliminated by an interpretive regulation (in 2004 maybe) and the 2012 Rule explicitly does not apply any of its requirements to projects.

    There is some discussion of the history of forest plans not helping with projects the way it was hoped. The response seems now to be viewing plans as something that has to be done rather than something that could help with project planning efficiencies, and therefore making fewer decisions at the forest plan level. What if the Forest Service looked at the forest planning and project planning process together and determined what kinds of plan decisions would be most helpful to project efficiency? Maybe a decentralized, autonomous way of doing business is not the most efficient way to operate in the complex legal environment we have now.

    One of the recommendations that I think is important for project planning is “involving the public more actively at the beginning of the planning process.” I don’t think this is yet a standard operating procedure.

  4. Thanks, MofT. You mentioned “overanalysis is because we are not using the environmental effects from implementing other similar projects in the past to improve our ability to reduce analysis in the future.”

    What you are talking about might be two things that were under much discussion at the time.
    (1) people not sharing their analyses or not wanting to use others’ analyses of what seems to me m/l the same project. This is what Fred Norbury used to call the “cobbler shop” model of NEPA, when a “Nike factory” model might be more efficient but absolutely contrary to agency culture.
    (2) monitoring effects and using them in the next analysis. This is super rational and even part of the 2005 Planning Rule (plan, do, check, change and all that). In the distance of retirement, I now think that people doing the NEPA already know the impacts, or not, of similar past projects. It would certainly be interesting to take previous projects in a highly litigated area (say Montana) and monitor the past effects and see if it makes any difference in the legal outcomes.

    Are either of these what you meant?

    • Yes – thanks for providing that additional type of detail. I remember a culvert replacement project that I was assigned to do the NEPA work on. My forest had just combined with another forest, and due to retirements, the “other” forest’s business rules were being applied to both forests. One of those business rules was that culvert replacements required an EA (which was more restrictive than the FS Manual). This was a major culvert on the same road where we had already replaced one other major culvert and we had done a similar project on another road system in the last 5-10 years (but before the current ranger arrived). All were done with CEs, and as long as we coordinated things with the small community that would have to use an alternate route to get to town for a few months, and followed all of the Best Management Practices, things were fine. I convinced the ranger that based on the effects and the “results” of those other projects that we did not need to do an EA – it was not easy to convince him of that, but he also needed to get that NEPA done and get that culvert replaced before it failed.

  5. At the risk of creating an apocryphal story, about 25 years ago, during oral argument in one of the spotted owl lawsuits, a Department of Justice lawyer was putting forward her best case for her Forest Service client. One of the appeals court judges interrupted her: “Why doesn’t the Forest Service just explain its decision as the Administrative Procedures Act requires?” Her candid response: “The Forest Service has always had a problem with the Administrative Procedures Act. Its foresters are well-trained professionals who don’t think they need to explain their decisions.”

    • I’ve seen more decisions with good decision rationales than not (of course in my work I tended to be involved in potentially litigated projects that received extra attention. But in the projects that we’ve looked at on this blog also, they have seemed pretty clear.. and many decision makers are not foresters … so.. maybe this has improved in the last 25 years..

  6. “The Forest Service has always had a problem with the Administrative Procedures Act. Its foresters are well-trained professionals who don’t think they need to explain their decisions.”

    Yep. What we used to refer to as “professional arrogance,” or as Dale Bosworth once called it “our professionalism.” Dale and I were chatting in his Regional Forester office, most likely about analysis paralysis and process gridlock, when I brought up the first terms. Dale said that he had recently (then) connected the dots between the two perspectives.

  7. Dave.. I think the simplest explanation might be that Dialogos isn’t paid to keep up the site. IMHO the Safety Journey to authoritarianism is a big stretch…


Leave a Comment