Forest Service EADM Workshop: Region 9 Summary

I’m going to start going through the write-ups for each Regional EADM Workshop and see what we can find in terms of issues and ideas for improvement.

I started with Region 9, linked here, and noticed that our own Tony Erba was involved. Hopefully, he will weigh in with his own thoughts. For the purpose of this discussion, I have taken the summaries produced by NFF and selected some points. Others are welcome to add their own from the report, or from their own experience. After we go through all the Regions’ reports, we can talk about the FS has done to deal with these issues. I don’t have the whole picture of what the FS tried and how it worked, but we can piece it together from my own memories and those of others.

Here’s what I’d like to see from commenters: 1) questions or additional description and your own experiences of what I summarized, 2) interesting things I left out from the report (it’s a detailed report, so I confess that I probably missed many ideas), 3) suggestions for different categories.

Here are the current categories:

I. Same as Previous NEPA Improvement Efforts:

FS is risk averse and overdoes documents.
Lack of consistency among units.
Use of jargon
Turnover- no steady hand to guide process, time lags to find new people
Lack of staff
Staff not motivated
Not using contracting
Not good and early collaboration
FS has bad writers forest plans not decipherable
Make it easier to find projects on web

II. Potentially New:

Poor quality of, and need to share data and maps
Disconnected decisionmaking from communities
Excessive use of EAs when NRCS doesn’t need to for the same kind of work.
Partner resources underutilized
Small non-controversial projects not getting done.
Special Use (SUP) authorizations are slow
Inaccurate and inconsistent data in databases and analyses

III. Not Related to EADM but Still Concerns:
Stop closing roads and trails
Broken web links
Lack of signage at picnic tables and trailheads website difficult to navigate

IV. Improvement Suggestions:
Annual Meeting for better communication on project planning and status
Make better use of partners to do work.
Sustainable Forest Certification to reduce litigation.

4 thoughts on “Forest Service EADM Workshop: Region 9 Summary”

  1. Thanks for posting these and making a go at summarizing the large volume of information! It’s interesting to me how some of the things that are suggested would possibly require more staffing in different areas than we currently have. It is interesting that some things that I see mentioned frequently in the west are not mentioned in this document – letting resource specialists go on fire assignments (which lengthens the NEPA process); not having dedicated analysis teams. The notes about slowness on smaller permits, etc. always puzzle me because I have worked so many places where we had an effective way to do those things simultaneously with larger projects and we had the strong working relationships that allowed us to do that too. As with so many things in the FS, there is a lack of accountability. The statistics on some of the smaller permit items nationally are appalling – seems like there should be some line officer accountability there – but we don’t seem to be measuring those metrics (but maybe now we will be?).

  2. Because I’ve “been there and done that” I can’t get too excited about getting very deep into this, but I’m glad someone is. Mom’s comment on “line officer accountability” did remind me of an impression I’ve had in the past: there is little institutional learning among FS managers because they don’t have to live with their mistakes. They are often gone by the time their work gets remanded by a court, and those failures don’t keep them from advancing. (Which also reminds me that these are sometimes not even seen as failures, but instead blamed on litigants or judges.)

    Also, if the Forest Service really believes that there are situations where there should be shortcuts because of limited environmental impacts, they should use the process provided under NEPA to do the analysis needed to create categorical exclusions. I don’t think begging Congress for help contributes to collaboration, especially where it allows the agency to ignore real environmental impacts.

    • I’m not sure that the FS is “begging Congress for help”. Congressionals seem fully capable of stepping in on their own, e.g. oil and gas CE’s and expanding Farm Bill CEs beyond insect and disease. In fact, the lawyers for those activities may well be capable of suggesting statutory fixes without much help by the FS.

      I personally helped with two efforts through the administrative process to get CE’s, the ones known as small timber harvest and the HFI CE’s. They used similar approaches to “the process” and both were litigated, with one coming out OK and the other being undone by the courts. If you take a longer view at the old HFI CE’s you see a similarity to the current Farm Bill CE’s. So another way to look at it is “court cases aren’t the end of the world, Congress also participates in the formulation of policy” in other words, checks and balances are working!

      Based on my own experience, problematic projects have the SO, the RO, and for really difficult ones the WO involved. Appeals in our Region always had involvement by OGC and often the Appeal Deciding Officer would take their opinion over our own (the RO staff’s or appeal review team). So I conceive of most of these project decisions (and I’m talking here of ones likely to be litigated) as a group effort.. OGC RO/SO Appeal Deciding Officer and so on. It would be unusual that a line officer would be hanging out on their own (and therefore solely responsible) for a (difficult, potentially litigated) decision.

  3. Those are good points, but my experience was a little different. When I worked on appeals and litigation in R6, it was not standard procedure to involve OGC in appeals (but that was long ago). In R1 I was not in that kind of direct role, but my impression was that OGC had enough litigation to keep them from being involved in appeals/objections. And there were district ranger decisions that never got reviewed above the forest level.


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