Fuels Treatments, Rx Fire NEPA Timeline

The Property and Environment Research Center has a new report, “Does Environmental Review Worsen the Wildfire Crisis? How environmental analysis delays fuel treatment projects.” Highlights:

  • Fuel treatment projects designed to reduce wildfire risks, including mechanical treatments and prescribed burns, often take longer to implement than other U.S. Forest Service projects because they are more likely to require rigorous environmental review or be litigated.
  • Once the Forest Service initiates the environmental review process, it takes ​​an average of 3.6 years to begin a mechanical treatment and 4.7 years to begin a prescribed burn.
  • For projects that require environmental impact statements—the most rigorous form of review—the time from initiation to implementation averages 5.3 years for mechanical treatments and 7.2 years for prescribed burns.
  • Given the time it takes to conduct environmental reviews and implement fuel treatments, it is unlikely that the Forest Service will be able to achieve its goal of treating an additional 20 million acres over the next 10 years.

36 thoughts on “Fuels Treatments, Rx Fire NEPA Timeline”

  1. What’s interesting about this to me is the long timeframe and litigation of PB projects. This is interesting because so many news stories follow the “dumb local people don’t appreciate the wonderfulness of PB” narrative. But if PB is wonderful to the powers that be, why is it being litigated? It would be interesting to see who is litigating and why.

    • In my tracking of litigation over the last few years, I don’t recall any lawsuits that were specifically against prescribed burning. Also, most projects I’m reading about seem to be a mix of mechanical treatment and prescribed burning, so it’s not clear how anyone could separate them for this kind of analysis. I’m skeptical.

    • PERC has a longer report out now (25 pages), “How to Confront the Wildfire Crisis.”



      As summer approaches, wildfire season is already upon us. By early May,
      1.1 million acres had burned in the United States, double the amount that
      had burned at the same point last year. And with much of the West in the grips
      of extreme drought, we’re likely in for another year of smoke-filled skies and
      high fire danger.

      The trends are alarming. Wildfires now consume twice as much land each year
      on average than they did in the 1990s. More than 10 million acres burned in three
      of the past seven years, setting modern-day records. Last year, another 7.1 million
      acres went up in flames, three-fourths of which were federal land.

      Catastrophic wildfires are sparking bipartisan interest in active forest
      management to reduce extreme fire risks. Earlier this year, the Biden administration
      unveiled a 10-year strategy to ramp up forest thinning and prescribed burns in an
      effort to “confront the wildfire crisis.” If fully implemented, the plan would increase
      these activities by up to four times current levels in the West.

      But despite growing recognition of the importance of forest management,
      significant hurdles remain. Red tape and litigation can hinder even the most-needed
      projects, contributing to a 80 million-acre restoration backlog in national forests.
      And partnerships with states, tribes, and the private sector are needed to conduct
      restoration work at scale.

      This special issue of PERC Reports explores these issues in detail. As Jonathan
      Wood explains (page 12), reducing the forest restoration backlog requires addressing
      persistent policy obstacles. Eric Edwards and Sara Sutherland (page 20) describe
      how environmental analysis can delay fuel treatment projects. And Hannah
      Downey (page 34) explores how federal agencies can partner with states and other
      neighbors to mitigate wildfire risk.

      Other challenges loom large. J.D. Tuccille (page 26) describes how innovative
      markets for wood products can help support needed restoration work. Tate Watkins
      (page 40) explores how prescribed fire can make forests across the country more
      resilient. And Judson Boomhower (page 22) discusses the economics of fire
      suppression, with some surprising results.

      The lesson is clear: Fixing America’s forests will take more than just spending
      money, as the Biden administration’s plan proposes to do. Truly confronting
      the wildfire crisis will require tackling the thornier policy obstacles explored in
      this issue.

  2. The data presented in the PERC report undermines its own message. The data in fact show that environmental review is only one of several factors that lead to the duration of planning prescribed burns and mechanical treatments. If we extract data from the figure Steve reproduced above, we can calculate how much of the time between NEPA initiation and treatment initiation is spent in the NEPA process (red-orange bar in the figure above). Most of the time is after NEPA has been completed:

    Mechanical Treatment CE – 73% of time from initiation of NEPA to treatment is after NEPA is completed
    Mechanical Treatment EA – 59% ”
    Mechanical Treatment EIS – 50% ”
    Mechanical treatment overall – 64% ”
    Prescribed burn CE – 79% ”
    Prescribed burn EA – 70% ”
    Prescribed burn EIS 62% ”
    Prescribed burn overall 72% ”

    Environmental review is obviously one of several things that must be done in order to initiate a fuels treatment, its apparently not as time consuming as the other things that must be done, and its not clear that it in fact represents the most important barrier. Time spent doing “NEPA” includes time spent planning projects, engaging with stakeholders, and deciding between multiple competing priorities – work which must be done regardless of legal requirements, and is inherently time consuming – yet it apparently represents a minority of the total time to treatment initiation. Something happens after NEPA and before treatment which takes longer than environmental review!

    • Excellent points. Especially that an acceptable alternative to NEPA procedures would still demand a lot of the same things. The authors imply that the “something” that happens after NEPA that causes further delay is litigation, but we have seen elsewhere that the proportion of projects litigated is not that high.

      • Yes Jon, their data (actually data that I published, but its really the agency’s PALS data) shows that litigation is pretty uncommon, although a bit more common for EISs (18% of EIs are litigated). Litigated projects spend more time after completion of NEPA review than non-litigated projects – their table 4 shows this. But non-litigated projects still spend the same or longer after NEPA review and before treatment than they spend under NEPA review, so we can’t really blame litigation for the post-NEPA delays in general.
        Their data also shows that projects that end up being litigated take longer under NEPA review than projects that don’t. This suggests that some unobserved variable (perhaps project complexity?) might cause all three of longer NEPA review processes, longer post-NEPA processes, and litigation, rather than all of the additional delay of NEPA projects being the result of litigation.

        • Forrest, this seems like a bit of a philosophical discussion.
          Claim: litigation of projects takes time. Evidence: working through the litigation process by FS employees.

          Your claim: It’s only one of many post-NEPA processes that take time.

          Logically if we call litigation A, and other post NEPA holdups, B, then Time to Project Initiation = A +B. So both contribute and both can be discussed as factors leading to delay of project implementation.

          Also, there is research (can’t remember what study) that shows the prospect of litigation causes FS employees to attempt to bullet proof, which takes more time during the NEPA process.

          Here’s my model FWIW. Some litigious groups make clear they don’t like projects (this seems to be recurrent in Montana for whatever reason, see the GAO and other studies). FS folks keep in mind that they’re probably going to court so try to do everything perfectly. Which in itself takes longer as does the litigation.

          So if I were to design a study based on my hypothesis, I’d take a sample of fuels projects of about the same acreage, or two sizes “large” and “small.” Then I’d pick parts of the country known for frequent vs. less frequent litigation .. presence or absence of litigious groups (that litigate these kinds of projects). Then we could compare length and it would include the impacts of bullet-proofing.

          • Sharon,
            I think we agree and both disagree with PERC (or at least their press release/summary). Their summary identifies only environmental reviews as a problem, the data they present in their report tells a more complicated story and leaves many important questions unanswered. It doesn’t support the political story (i.e. “gut NEPA to enable forest restoration”) they want to tell except in the most general fashion.

            • While you may or may not be right about the “gut NEPA” political story (I won’t pretend to know) I think this is an interesting comment.

              The subtext is certainly that NEPA is a problem. And that itself, as you say, is probably a bit overstated.

              The conclusion of the report itself proffers two main points on my read, that is one about how extension of CEs for wildfire and fuels work has not done well in the past and thus two that the extension of CEs recently is unlikely to enable any kind of meeting the agenda for treatments in the present admin. Those points seem supported by the data.

              But anyway, and here’s what’s interesting, the jump to the idea that they’re claiming “we better gut NEPA”. Respectfully, this is a kind of leap that makes meaningful reform and even incremental improvement impossible. The 2020 CEQ regs may have had some eyebrow-raiser lines, but it wasn’t all travesty, and some corners jumped to the ‘defense’ of NEPA in a way that implied any change would be for the worse. And that’s no more supported by the data than “gut NEPA” is by this PERC report.

        • Fear of litigation, and all that hard work and effort being tripped up in a “Gotcha!” moment. Far easier to find a single fatal flaw, and win a lawsuit, than to see…what is it? The forest for the trees?
          So no, projects may not frequently be litigated, leading to longer timelines. But there is a fear of it, that results in over analysis, analysis paralysis, or simply drawn out work. Add in a Federal exodus, overworked District ologists within the FS, and the lack of funding or difficulty in finding seasonal workers, and that is the result.

          Overall seems a broken system with no foreseeable solution, given current status. It is not something we can solve with “Planning”.

    • Few notes:

      One, the report and analysis appendix, are, of course, slightly less sensational-sounding than the infographic. It substantiates that NEPA does indeed take time, but I think there are different directions to run with that information. While I don’t doubt PERC is not in love with NEPA, the report itself acknowledges that NEPA is not the only factor. Note that it mentions the timeframe on prescribed fire being relatively fickle, weather based, for instance.

      Two, for EAs and EISs, the NEPA step is still the single largest step, chronologically, and that is itself of interest, irrespective of there being other steps. What is produced during that process that makes it worth taking that amount of time? That’s the question. I’ve seen attempts at answers, but it doesn’t really lend itself to empirical investigation easily, and most answers i’ve seen simply amount to “it allowed me or my group to advance a policy goal that hasn’t succeeded in advancing at higher levels”. Maybe that’s good, maybe not, but it’s not an unambiguous good produced by the NEPA process. The PERC report notes that “Advocates
      of the review process argue it “reduces overall project costs by identifying and avoiding problems that may occur in later stages of project development” a claim I’ve seen elsewhere, but i haven’t seen empirical support of.

      Three, this research doesn’t account for steps within NEPA (nor does any other, that I’m aware of, I don’t think that dataset exists) nor does it disaggregate the goings on between a signed decision and activity. As above, it notes that there’s stuff like weather and contracting to consider, but I don’t think this dataset exists either.

      Finally, the time it takes to implement may point to additional needed improvements. The “but look at that other problem” tack isn’t really a great way to argue, imo. It seems, loosely, like there’s a “NEPA is fine, keep it as is” school of thought that is fond of pointing to other problems, but you can coherently hold that NEPA as currently conceived creates delays and that contracting does as well. Walk and chew gum, etc.

      Frankly, PERC faces an understandable credibility gap due to the obviously tenuous relationship between “property rights” types influenced by the austrian-school economists and their descendants, who yeah, don’t exactly strike the mildly informed observer as having the best interests of public lands at heart, the very concept bordering on anathema in those circles. But, and this is important, they make legitimate points here. On a first read, the dataset is credible, and even if the conclusions wink and nod a little too hard at NEPA being the issue, a response that says “well other stuff takes time too” is far from sufficient.

      To wit, some questions that need answering:
      – what is it that could streamline NEPA agreeably? (note, no cheating by saying “only support projects the public fully supports” as if that’s a live option in the land of multiple use and polarization)
      – to answer that: what steps in NEPA take so dang long? why?

      – what takes the time between implementation and NEPA? why?

      – what data do we need to answer that?

      – why is the NEPA process perceived as a problem? (note 2: no cheating here and saying that “it’s only perceived a problem by those trying to make a quick buck logging the forest or whatever” as the NEPA problem seems to be treated as a problem whenever it slows down your pursuit of a desired policy goal. deeper-green ENGO groups will argue for streamlined approaches when the action is in line with their agenda, while extractive interests will dig in their heels for site specific EIS detail when the proposed action cuts against their interest)

      – related to the above: what is the value added by the NEPA process? are there other ways to achieve that same good? are there ways to get at that good more quickly within NEPA processes?

      – are there ways to cut the gordian knot and produce a planning system that doesn’t scrap NEPA and NEPA’s faith in rational-actor stepwise planning but also doesn’t create weaponizable hoops?

      (I don’t pretend one person or even a few can answer these all at once, but you get the idea)

      • Anonymous,
        Those are the same questions folks have been having since Process Predicament in the (90’s). As Fred Norbury said “we say NEPA takes too long and costs too much, but we don’t know how long it takes or how much it costs.” So that led to PALS and here we are.

        I think your questions might be a good starting point for the co-designed and co-produced research effort.

        ” what is it that could streamline NEPA agreeably? (note, no cheating by saying “only support projects the public fully supports” as if that’s a live option in the land of multiple use and polarization)
        – to answer that: what steps in NEPA take so dang long? why?

        – what takes the time between implementation and NEPA? why?

        – what data do we need to answer that? “

        One thing that has changed since the 90s is that, as you point out, ENGOs and their political friends are for streamlining projects like windfarms, solar installations, and powerlines; and possibly mining for key minerals. So we are seeing the Admin push quickie NEPA without (apparent) pushback by the usual groups. If our friends at CBD go after these projects, we might see all this up for a much broader discussion than just the FS and fuel treatment projects.

        • It’s not cheating to “support projects” by taking others off the table at the forest plan level. Why not have a discussion during forest planning of what places and practices are going to be most strongly opposed? And why wouldn’t a good manager take that into account in some way in the forest plan?

          “So we are seeing the Admin push quickie NEPA without (apparent) pushback by the usual groups.” I must have missed (or forgotten) this story.

          • I’m sure that the relevant folks know what places and practices will be most strongly opposed, and by exactly which groups. And I’m sure they take that into account as they plan each project, even with 30 year old forest plans.

            As to the statement about quickie NEPA, I’m talking about renewable energy projects with the BLM, and I heard it through the Retiree Information Network, not the media.

          • 1. forest plans already do that in the form of suitability determinations, standards for management areas, and the like. I’ll grant that perhaps they could do more up front than many do, and remove some controversy that way. But the “zones of agreement” or whatever that these represent are hardly respected as is, so I don’t think there’s any reason to believe that there wouldn’t be a push from certain corners to oppose projects unless, well, pretty much every activity stopped.

            2. So the cheating dig comes from the idea that you can’t claim the problem with NEPA isn’t how it’s interpreted or implemented at present, but in fact that projects are treated as controversial and that NEPA would be easy and simple (all present requirements intact) if only everyone would see the light and stop proposing things that certain groups disagree with?

            3. Controversy isn’t actually a particularly useful barometer of the effects of a project. Controversy can be created quite easily. In the present context you can take a project that meshes with the plan, is supported by monitoring, and is on lands determined suitable (that is, it’s within the zones of agreement for certain activities “codified” if you will in the plan) and still run afoul of controversy in turn leading to a drawn out NEPA process.

            • NEPA defines “controversy” in the context of the (scientific) nature of effects, not how many people disagree with the project.

              Also (and I’d like to hear from practitioners about this), the timeframes measured here probably don’t account for what else everyone on the project planning team is doing (and include delays such as filling a vacancy, which may take months). The more things that are going on, the longer it looks like they all take. A more useful comparison would be how many hours are being spent.

              • I suspect that the real source of delay in environmental analysis has to do with agency staffing and turnover, including details and sending staff out on wildfire assignments. In my experience, it’s not really the requirements of NEPA that cause delay (the process of analyzing direct, indirect, and cumulative effects is a well-worn path that can be [but often isn’t, another aspect of the problem] taught, standardized, and repeated), but rather the fact that there simply aren’t enough “butts in seats” to do the analysis in a timely manner.

                • See now this would be an interesting thing to have data on. FWIW, as respectfully as I can say this, I think this idea that it’s just staffing problems is a bit of a diversion. It’s practically a creedal statement among those for whom any change from current NEPA requirements will be a change for the worse, but let’s unpack it. I recognize that it is meant well, like don’t just beat the agency / personnel over the head but i think it kind of passes the buck to a ghostly no-mans land of “staffing and budget problems” which is where you go when you want to criticize but not actually have things change.

                  “the process of analyzing direct, indirect, and cumulative effects is a well-worn path” Many if not most mildly controversial NEPA processes are tagged with the “do more analysis, this is inadequate” line. The goalpost of analytic adequacy is always and forever moving. So how exactly is it a well-worn path? the basic concepts are easy enough, but cumulative delays can be easily accreted through bolstering your analysis between scoping, draft, and final.

                  “taught, standardized, and repeated” training is probably a hit and miss thing, but standardized and repeated, that’s an interesting one. a CE is, in many ways, the most standardized and repeatable form of NEPA, but CEs aren’t super popular in many corners. what could standardization and repeating begin to look like?

                  In a more irenic tone, would wide ranging standardization “lock in” those goalposts for analytical adequacy? Difficult as it could be, some degree of standardization could prevent vague claims of needing to do more analysis from carrying the day. maybe.

                  Side thought, if your analysis ties back to your forest plan with what indicators you use, shouldn’t that itself prevent that goalpost from moving?

                  • My experience (granted from carbon) is that no analysis is enough if you have the “wrong” judge. And judges are unlikely to say “well if a 30 page analysis for a 500 acre fuel treatment project is good enough in New Mexico, it should be good enough in Montana.” Because really smart litigators are likely to point out all the differences and the “need” for more analysis, due to ..whatever. So to me the problem with the standardization idea is that it works until it goes to court. Which means it doesn’t really work for ones going to court.

                    One approach I liked is to do “what needs to be done according to the regulations and best practices” but not bullet proof. Then go to court and have the judge tell you directly what more is needed. This is quite a bit less “bring me a rock, no not that rock” ish. But not popular with USG legal folks, because they want to have the best chances of winning (the first time). That’s a whole ‘nother discussion; are agency and OGC and DOJ goals aligned? I wish I could get retired OGC and DOJ folks to participate in TSW, but so far I have not found anyone who could be cajoled into it.

                    I greatly appreciate SJ and Ted and others who contribute to TSW because otherwise we would be missing that perspective as well.

                  • A, do YOU believe the Forest Service has sufficient -ologists, writers, and planners to do the job? How many vacancies in these positions does your local national forest have? How many actings? How many district rangers have you had in the last 3 years? Does your forest supervisor know your name, your forest’s dominant plant association group, or its fire regime?

                    In my experience, while many agency personnel are good people with good hearts, there simply aren’t enough qualified people to do the job of managing our national forests. This isn’t a dig at those folks, its just an observation that there aren’t enough of them.

                    As someone who is actively helping the Forest Service do better NEPA, I *do* believe that the process can be improved. And as a professor of law, I *know* it can be taught. So yeah, I believe it can be taught, standardized, and repeated. Do you disagree? If so, it seems that your position contributes to “inefficiencies” rather than addresses them.

                    CEs are one tool. But they are not the right tool for the large-scale forest health crisis we have facing many of our national forests. And, while I’ve seen hundreds of CEs in my time, I’ve never seen the same CE used the same way twice: there’s always some different thing a line officer is trying to do with them, which often lands the agency in court. The fact that OGC – the agency’s lawyers – can’t explain in a consistent, replicated manner how to use CEs is also part of the problem. (Full disclosure: I’ve never been impressed by OGC, regardless of how nice some attorneys there are.)

                    Finally, agree with you, A, that implementing the forest plan should prevent the goalpost from moving. Problem is, nearly all of our forest plans are decades out of date: the goalpost has already moved, but static forest plans in many ways keep us tied to something that is no longer appropriate or realistic in the face of a warming climate.

                    • Interned w/R1 OGC back in 2016. Eye opening. IMHO it’s the same dynamic for OGC as it is for the rest of the USFS staff. 5 attorney’s for ALL Region 1. And get this, only two, Alan & Barb, actually worked wildlife/natural resource. Jody, the present director largely worked water issues. Mark, the director when I was there was fending off multiple RS 2477’s suit’s from tin foil hat nut-bars. The fifth attorney, I forget his name, worked contracting.

                      Takeaway, we don’t get to have nice things b/c we’d rather make government small enough to drown in a bathtub. If there isn’t a free-market solution then most politicians aren’t interested.

                • There is certainly a lot of that type of staff “churn” that slows things down. Right now it seems to be worse than usual in terms of details/temporary assignments. The vacancy rates in the Forest Service for permanent positions are 20-30%, so that doesn’t help either. And right now there is a national hiring event for foresters going on in the Forest Service and 50% of the people being offered jobs are declining them. And most of those jobs are being offered to current FS employees, so when they move, additional vacancies are created…sigh…

              • Jon, I’m not sure that judges use the scientific nature, or perhaps people who disagree can always find or generate controversial science? In practice, it might be the same thing.

            • Anonymous, I think you are touching upon something about trust. There are certain groups that if you think you have an agreement, they may simply move the goalposts as one set of results are achieved via plan. Two bites at the proverbial apple. Given that, it is absolutely rational for the FS to not close itself off to choices in the plan. Because people may well change their minds in the currently 30 year life of a plan.

              So this indeed might be the vicious circle of trust.

              I’m not a fan of NFMA planning as currently constructed at all as everyone knows. Locking agencies in to decisions based on the “best science” when science is endlessly evolving..and writing EIS’s with effects to the gnat’s eyebrow for projects that often never happen.

  3. If they stuck to RxB it, there would be less litigation. But, when you insist on including an ATV rider and logging 20K acres, things get muddled with details. Plus, AQ is truly emerging as a public health and safety crisis.

      • There are now abundant peer reviewed papers on the detrimental health impacts to populations, both near and away from fire centers. Some are better than others, but feel free to peruse:

        In California at least, while the insurance companies may force the hand of policy, management, and regulation, the short and long term health impacts on the general population are what we should be (and will be soon) talking about.

        • Yes, I wrote about this in March..

          Now we know.. via many scientific studies, that wildfire smoke is bad for you. Perhaps we knew it then, but then it just seemed like part of life in wildfire-prone country. What has changed? Scientists have studied it extensively and found it to be bad for health. The same particles were always bad, but now scientific studies exist to tell us that they are bad. I think of scientific interest as a flashlight. The world goes on, but the part that gets highlighted as “science” depends on who’s holding the flashlight. This is much discussed in the history and sociology of science literature, but not so much questioned day to day information sharing and reporting.

          And who is holding the flashlight is a complex multi-actor and institution process that is not well understood. If we look at relative funding for sociology of science, we can see why.

          What made smoke suddenly more interesting and worthy of research? Was it the fact that highly populated areas were getting more smoke? Was it the fact that suddenly wildfires were “due to” climate change and there’s plenty of money in climate change?

          If that’s the case, we should be glad wildfire changed to being framed as a climate change issue, rather than a natural process that interior Westerners should live with. Otherwise I guess we still wouldn’t know.

          • Yes, I do agree to all of that. And of course, there are all the historical anecdotes of up and down the west coast, valleys sitting in smoke and the horizon obscured all summer.
            Difference being, now there are just a few million more people around. I also think what made smoke interesting, besides simply being linked to anthropogenic climate change and new/extreme stressors on forests and fire-prone habitats, is technology.
            The ability to gather and analyze data, and a large academic base to work with it, tools like GIS and large databases, allow researchers to pursue these points on smoke/health, where maybe they weren’t able to before. I suspect it tracks well with recent environmental justice focuses. Similar to how forest research has gone from just looking at plots/stand(s) to utilizing remote sensing and LiDar data to characterize the entire landscape.

            All of this is a distraction, of course, from the immediate issue of pace/scale and doing Rx/Mechanical treatments, where needed. Which is why ultimately, the insurance companies are going to force everyone’s hand one way or another.

            • That makes sense, the tool can help you see the problem better or see different problems. I think of EDF and their methane sensing efforts.

              • I think people lose sight of the fact that people heated and cooked with wood on a near-daily basis until just a few years ago. Homes and valleys were filled with smoke almost daily as a result of these fires, and when field burning and wigwam burners became more common in the 20th century, the effect was often shared with others. Not to mention cigarette smoking. It was only recently that human contacts with dense smoke became an uncommon occurrence for much of the population in “developed” countries. Thank God for science and for taxpayers to cover the costs of identifying this danger!

  4. I believe that NEPA documents are only useful as a tool for litigators to stop projects. For years I read the term, “did not study enough” used to stop projects. Some projects are going to be litigated no matter what documents they are proposed under. I have bought small hazard tree salvage sales with 100 page plus NEPA documents that I believe nobody read in their entirety.

    • Bob: Unfortunately, total agreement. We are both old enough to remember when a handshake was contract enough; or two or five pages most, with one signature, depending on the job and lawyers involved. Then NEPA. Formed on the same day in the same town as the enduring ELI (“Environmental Law Institute”) collaboration. ESA, NOAA, and EAJA were natural off-springs. Then the predictable destruction of our public forests and rural forest industries and communities. In my jaded opinion.

  5. Podcast from PERC (Thanks to Nick Smith for the link)

    PERC Senior Fellows Sara Sutherland and Eric Edwards join the Pacific Research Institute’s Next Round podcast to discuss their latest research, Does Environmental Review Worsen the Wildfire Crisis?

    The episode explores how the federal environmental review process adds delay and expense to urgently needed restoration efforts meant to reduce the risk of catastrophic wildfire. While the review process is meant to protect the environment, in the case of forest management, it hinders important restoration work and can do more harm than good.


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