From Farm Policy News:
Politico’s Samuel Benson reported that “the Agriculture Department has quietly extended the public comment period for its controversial reorganization plan to Sept. 30, doubling the length of time provided for input on an initiative that has drawn criticism from both Democrats and Republicans since it was unveiled last month.”
“USDA released the plan for public comment on July 24 for a period that was originally set to last 30 days. A department webpage that earlier this week listed the deadline as Aug. 31 now says it is Sept. 30,” Benson reported. “‘The additional days in the comment period are to ensure everyone who wants to submit feedback, can,’ USDA spokesperson Alec Varsamis said in a statement. ‘This aligns with our original intent to hear from our stakeholders.’”
“Lawmakers from both sides of the aisle criticized USDA over its rollout of the plan, which calls for relocating much of its Washington-area workforce to five regional hubs across the country,” Benson reported. “Senate Democrats — led by Agriculture Committee ranking member Amy Klobuchar of Minnesota and Sen. Adam Schiff of California — sent a letter earlier this week urging Agriculture Secretary Brooke Rollins to extend the comment period to at least 60 days.”
Originally I wasn’t going to comment on the reorganization plan, but this extension makes it easier. Helpfully, the Rocky Mountaineers (Region 2 Retiree Group) forwarded the below comment from former Regional Forester Rick Cables, which I pretty much agree with. That being said, please use this opportunity to post links to your own comments, or your organization’s comments, and the rest of us will have a leg up on writing ours.. it’s always easier to edit than to write an original. My comments on his comments are at the end.
Here’s Rick’s letter:
Thank you for the opportunity to provide public comment on USDA’s Memorandum SM 1078-015, the proposed Reorganization Plan.
My name is Rick D. Cables, and I devoted 37 years of service to the U.S. Forest Service before retiring in 2011.
During my career, I served at every level of the agency, including as District Ranger in Arizona, Forest Supervisor in New Hampshire and Colorado, and Regional Forester for both the Alaska Region and the Rocky Mountain Region.
I remain deeply committed to public service and to the enduring mission of the U.S. Forest Service, which I continue to believe is the finest natural resources conservation organization in the world.
My comments are offered in the spirit of strengthening the Department’s reorganization effort, with specific attention to its implications for the Forest Service.
General Observations
I commend USDA for the vision, energy, and transparency that underpin this reorganization effort. The plan’s four guiding pillars are sound:
1. Aligning USDA’s workforce with financial resources and priorities
2. Bringing USDA closer to the people and communities it serves
3. Eliminating unnecessary layers of management and bureaucracy
4. Consolidating support functions for greater efficiency
These principles are essential to renewing USDA’s effectiveness, and I fully support their intent.
The Forest Service Mission
The reorganization of the Forest Service should be designed to strengthen the agency’s ability to fulfill its core mission: to protect and sustain the health of the 193 million acres of national forests and grasslands, while providing for their multiple uses.
While the agency delivers many important discretionary programs, caring for and protecting these lands—through stewardship, resource management, and wildfire suppression—is not discretionary. It is the fundamental reason the Forest Service exists.
I strongly support the principle of decentralization—placing employees closer to the communities they serve and reducing reliance on Washington, D.C. This was the very design envisioned by the Forest Service’s first Chief, Gifford Pinchot, who embedded rangers and decision-makers in rural communities across the West. That principle remains as relevant today as it was at the agency’s founding.
On the Elimination of the “Regional Layer”
The USDA plan contemplates eliminating the Forest Service’s “regional layer.” I interpret this to mean the removal of Regional Offices and associated staff, not the elimination of the concept of geographic regions themselves.
While it is true that Regional Offices have grown into large bureaucracies—averaging 300-350 employees per office in 2023—this was not their original purpose. The intent was for Regional Foresters to serve as the Chief’s delegated “field generals,” empowered to make timely, place-based decisions, and to build essential relationships with governors, members of Congress, tribal governments, and key stakeholders.
Removing Regional Foresters and their delegated authority would force controversial or complex decisions upward to Washington, D.C. This would have the opposite effect of Pillar #2—concentrating decisions in the capital rather than dispersing them closer to the land and the people.
A recommended alternative:
– Retain Regional Foresters and the existing regional geographic boundaries.
– Reduce Regional Office staffing dramatically, limiting each to a lean, strategic staff of 25–40 employees. This would reduce up to 2000 high graded positions.
– Reallocate the saved resources and positions to Ranger Districts and National Forests, where they will have the greatest impact on mission delivery.
This approach would preserve the critical role of Regional Foresters while eliminating unnecessary layers of bureaucracy, thus advancing Pillars 1, 2, and 3 simultaneously.
On the “Hub” Concept
The hub model may be well suited to agencies such as NRCS and FSA, which do not directly manage vast land bases. However, the Forest Service’s scale, complexity, and need for cross-boundary collaboration make the hub
model less appropriate. The agency’s mission depends on geographically based leadership and decision-making capacity.
Pillar 4: Consolidating Support Functions (Human Resources)
I offer particular caution regarding the consolidation of Human Resources (HR) functions. The previous USFS centralization of HR services in Albuquerque was intended to increase efficiency and reduce costs. In practice, it achieved neither and proved deeply unpopular among employees who often experienced inadequate service.
Rather than consolidating HR further, USDA should consider a distributed model:
– Embed HR professionals across field locations, Forest Supervisor offices, and other existing facilities.
– Utilize today’s advanced technology to coordinate, share workloads, and deliver consistent oversight.
– Close or significantly downsize centralized facilities such as Albuquerque, reducing lease costs and improving service delivery.
This would provide more responsive, place-based HR support, strengthen recruitment and retention, and align with the principle of bringing USDA closer to its people. Human Resources are critical to mission delivery and HR professionals will be more effective if co-located with field units.
Conclusion
In summary:
– Eliminate bloated Regional Offices, but retain Regional Foresters as delegated leaders with small, strategic staffs.
– Reinvest saved resources into field units closer to the land and public.
– Avoid overextending the “hub” model to the Forest Service.
– Modernize Human Resources delivery through distributed, technology-enabled staffing.
These adjustments would, in my view, preserve the strengths of the Forest Service, advance all four pillars of the USDA plan, and ensure that decisions remain connected to the land, the people, and the mission.
Thank you once again for the opportunity to provide comments. I appreciate USDA’s commitment to strengthening both the Department and the Forest Service, and I am hopeful these suggestions will be useful as the reorganization moves forward.
****************
I agree with Rick that RO’s have become bloated, but there is also a real question, as the Transformation process analyzed, of figuring out exactly where and how many people are needed, and what is the best structure for sharing. For example, one Forest hired a Tribal Coordinator. Does each Forest need one? Should some Forests share a position (like we used to do in R-6?)? How many would need to share? What’s the workload? Rick’s 25-40 could be mostly relational and not technical.. but then where would the technical expertise reside and how would it be shared? Just thinking about litigation, paralegal, and FOIA, plus specialized engineering skills and so on. I’m not sure the FS has even done a study of the different shared services now available and which ones work best and why.
Sidenote.. during some of the ASC drama in Region 2, Rick suggested our Region work with BLM Denver on HR and withdraw from ASC for poor performance. I don’t think this was possible but was a creative idea. This was probably when our new Forest Supe at the time, Dan Dallas, had trouble getting paid, and was probably 20 or so years ago. It would be an interesting case study for a public administration student as to why a federal agency could go so long, with a unit critical to success, with so many problems not getting fixed.
This was my comment letter (I did focus toward timber because I thought that would resonate with the current priorities):
Subject:
Secretary Memorandum: SM 1078-015
Comments on Department of Agriculture Reorganization
I am providing comments on the proposed changes in the organization of the Department of Agriculture. Most of my comments are focused on the Forest Service since I have experience within the agency. However, many of these comments relate to other agencies as well (such as NRCS). I am retired from the Forest Service after a career where I worked at three different levels in the agency – the District, the Regional Office and the Washington DC Headquarters.
The organizational structure of the Forest Service has been in place for much of its 120 year history. It has functioned well over time, through many changes in society, resource needs, etc. The Regional Offices play a critical and specific role in mission accomplishment.
The Regional Office (RO) level is the level for work specialization and knowledge. The Washington Office (WO) works closely with the Executive Branch and Congress, responding to inquiries, providing testimony, and relaying direction and interpretation of laws and regulations to the Regional Offices. This specialized role of the Washington Office is the reason it is critical to retain staff in the Washington DC offices.
The RO is the next critical level in relaying direction and interpretation of laws and regulations to National Forests and Grasslands. The staff at the RO level have niche skills and specialties that are critical. Most of these individuals have experience at the field level and understand the aspects of resource management (i.e. timber sales, prescribed fire, wildlife habitat restoration, watershed restoration, recreation management, etc) accomplished with respect to new and ongoing laws and regulations.
There is also a chain of command of accountability from the WO, to the RO, to the Forest. Each of the Regional Offices has a portfolio of a reasonable number of Forests to provide oversight, Forests within a geographical Region that have similar issues and stakeholders. Among other things, Regional Office role is to help provide a Regional, broad-scale approach to stakeholder and partner relations. For example, Forest Service Regional Offices in Portland and Missoula are critical in establishing and maintaining relations with timber companies that work across a Regional scale, some state-wide and many across several states within a Regional area like the Pacific Northwest. A HUB in Salt Lake, for example, would have great difficulty in maintaining these strong relations with companies and stakeholders across a dozen or more states. With varying issues and ecosystems, maintaining up-to-date knowledge and expertise would be nearly impossible.
From a National Forest perspective, although the individual National Forests have local knowledge and local relations, they can’t keep up with Regional issues and relations while still getting on-the-ground management completed. Currently, the Regional Offices provide that broader perspective to Forests so they can be consistent with those Regional needs and deal with issues in a manner similar to other Forests.
Moving Research to Fort Collins – The Forest Service has a broad scope of research work across the nation. Most of these research facilities have laboratories that are designed and staffed for the variety of research needs. Combining all of these research labs (with the exception of two – Fire Sciences Lab and Forest Products Lab) into one location, is expensive and will not meet the research needs. Research is often focused on ecosystems in the geographic area where the lab is located. If this research was to continue, travel time and costs would add even more to this relocation. In addition, Fort Collins has a very high Cost-of-Living Allowance for employee salary – almost double the amount of many of the current lab locations. This proposal has no basis in need – it only threatens the research being conducted and raises costs.
Overall, this reorganization makes no business sense. It is not “fixing” any problem; the cost of transfer of station for a very large number of employees will be extraordinarily high, taking money away from timber management and other on the ground management; increasing salary costs for moving people to areas with a higher cost of living allowance; and greatly increasing the geographical and social span of networking. No HUBs are located in the Pacific Northwest – Washington, Oregon, Idaho, western Montana – an area where there is intended to be significant increase in Forest Service timber production. None of this is needed or makes any sense at all.
Signed,
Kristine M. Lee
I generally agree with Cables’ comments as modified by Sharon, with a couple of caveats:
o As Sharon suggests, care should be taken in decentralizing policy-related positions such as those involving appeals and litigation. These are areas where letting a thousand flowers bloom can be harmful, especially since agency opponents will seek out and attempt to exploit inconsistent (or at least arguably inconsistent) approaches and decisions.
o As to devolving positions to the forest level, has anyone asked the forest supervisors what they think of this? I’m guessing just about every forest is shorthanded, but many are probably shorthanded in different ways. Suddenly having to manage dozens of new staff dumped from the region may not be a task every FSup eagerly wants to embrace.
That is a pretty good concept. I think the concept of a small Regional Office that is relational, not technical is interesting.
A small office, with lots of power, authority, and connections with other agencies, politicians, etc would be a very powerful organization. I suspect it would drain “power” from Forest Supervisors. Don’t know if that is a good or bad thing.
As to what to do with technical folks; when I worked for the Park Service they had a Denver Service Center that served the entire system. The Park Service even set up teams in Denver that focused on different regions of the park system.
Having that office in Salt Lake City would work in terms of travel time and airline connections serving the west.