Reminder: why we are interested in “permitting reform”? 1. BLM and FS authorize energy projects, 2. think tanks involved have really smart people and more political clout than traditional forest groups, but 3) my experience with Coastal think tanks is that may not be talking to NEPA practitioners. So they have fun and novel ideas that may actually get implemented, and maybe we can contribute by some ground-truthing.
As I’ve pointed out (yes, I know, tediously) before, there seems to be a thread of “if only agency practitioners did their jobs better” that I first noticed at CEQ.
CEQ: your documents are too long. Agencies: but case law requires it.
CEQ: programmatics should be used more. Agencies: they generally don’t do much in practice.. suck up a lot of time and go out of date readily.
(Note that recently the Biden Admin said it had to redo an LNG analysis as it was out of date after five years (not sure it was a NEPA analysis, but still); if it takes three years to do a programmatic.. you do the math)
CEQ: if you only did better public involvement, you wouldn’t have litigation.
What these views have in common is a kind of punching down on the lowest ranking people in the system, and not looking at the problem as real-world policy disagreements that need to be ultimately settled through political processes.
Anyway, let’s check out what BPC has to say.
The Bipartisan Policy Center recently published “Finding the Goldilocks Zone for Permitting Reform.” and if TwitX is to believed, folks from there are currently making Hill visits.
How does BPC characterize the “permitting reform” quest?
A more efficient permitting system for energy infrastructure would reduce energy costs, increase energy reliability, increase quality of life, and reduce emissions.
One could argue that “a more efficient permitting system for fuel treatment projects and prescribed burns would reduce risks of catastrophic wildfire and associated safety, health, watershed, wildlife and infrastructure impacts.” So maybe these would be relevant to other kinds of FS and BLM work?
They used stakeholder roundtables to help develop and rate the recommendations across two dimension: Effectiveness and Controversy. Let’s see what they came up with. It’s kind of a neat approach. So let’s see what we think of these.. I’ll post each set of recommendations in a separate post. We can discuss and I’ll give feedback to the BPC.
It seems to me that the question facing energy infrastructure is “why do we have to have this here and impact my community and wildlife and so on?” It doesn’t seem to me that any of this really answers the question of “why here and not there?”
If we are talking about energy infrastructure (onshore and offshore wind turbines, solar installations, transmission lines), it looks like their most promising is:
Conduct and provide resources for extensive community information hearings that address public comments and concerns of the community .
Which to me is a bit like “do public involvement better”.. which is good, but hard to say it increases efficiency in any way. Some people just don’t want projects no matter how they are educated. I’ve had grumpy people turn around with more information, but at the end of the day that’s not what delays projects.
I also thought it was interesting that BPC thought that this.. which sounds a bit like the successful Blue Mountain Partners in our world:
Establish a monitoring committee for individual projects, comprised of local stakeholders, that ensures standards are met and provides an avenue for continued public engagement for the life of the project [Pg. 21]
Here are their 3’s..
Require or incentivize agencies to engage stakeholders before developing a public notice of intent to prepare an Environmental Impact Statement [Pg. 23]
This is interesting. Right now it seems a bit random. Like the FS probably does before an EIS for a large vegetation project; and maybe that counts for the national OG EIS, but I don’t think it helps increase “efficiency”.
The underlying idea seems to be “if only agencies had better public involvement processes, there would be less resistance and projects that are unpopular in some quarters will move forward readily.” I think good public involvement processes are important, and I also know that the FS and BLM have pretty robust ones, and there are still disagreements about the project at the end of the day.
The funniest one to me was this one, which they fortunately rated as “not worth discussing”.
Establish commissions to advise agencies on the design, implementation, and evaluation of public participation processes [Pg. 24]
Increase efficiency by .. establishing commissions!
These ideas seem to reflect the “if practitioners only did it right, there wouldn’t be a problem” school of thought.
Next: Linear Infrastructure
It’s interesting that they only came up with ratings of 2-5 – no 1 (which they would have called what?).
The question of where to put something should be based on a decision process that considers alternative locations. That would have to be a larger scale programmatic planning process. (Maybe that would have gotten a 1?)
You again disparage the “coastalness” of think tanks but if they are just reporting on the results of more diverse roundtables, wouldn’t that tend to minimize any bias?
Yes I think some programmatics may be useful. The questions are: which ones, for what, for how long, and does the expense justify the cost savings further down the line. My memory is that it becomes kind of a slogan for some folks.
And no, I didn’t look at who exactly was at the roundtables. I’m not disparaging them.. I think they have good points of view and really smart people. The problem is when folks gather around and think that they are the only point of view or are more expert than anyone else. If we believe diversity of skin color, cultural backgrounds, and gender are important, why wouldn’t regional diversity also be important?