FS Retirees Don’t Want the Forest Service to Move to Interior
The NAFSR folks wrote this letter.I don’t think that this is surprising to anyone.
Interestingly, they have a section about how wildfire and the rest of land management need to be together. I think that that ship has sailed in Interior.
Our experience with government reorganization efforts shows them to be disruptive, costly, and often ineffective at achieving desired efficiencies. Fully implementing transfer of the Forest Service to DOI would likely take years, necessitate Congressional action and agreement about modifying multiple existing legislative mandates, cost taxpayers a lot of money, and distract from accomplishing important work on the ground.
We fail to see the compelling need driving this voluntary acceptance of disruption, cost, and distraction. Any objectives for which the proposed transfer is aimed would seem to be better achieved, through a much shorter path, by working within existing structures.
FWIW I am totally against moving the Forest Service to Interior. At the same time, I’m not so against reorganization in general. I actually worked in a recently combined agency (CSREES, now NIFA, which was formerly CSRS and Extension), and I could give advice on how not to do it. Still, my observation was that once folks were hired who had never worked in the old agencies, it was as if the reorg had never happened. Was it more “efficient”? I don’t know. Did it get extramural extension and research to work together better? Maybe. But to my mind, it could have been improved by simply funding joint (research and extension) projects over independent projects. Anyway, those two agencies are not at all like the FS and BLM, for a host of reasons. Perhaps the most relevant one is that there are 30K or so employees who would have to adjust instead of a handful. And the work of the FS is highly visible to the public. On the other hand, combining staffs within one agency different than moving a whole agency in toto to another department.
My basic point is that in my experience, not all government reorganizations, at the end of the day, are ineffective and make things worse. They have to be carefully thought out and carefully managed, neither being easy to do.
In fact, it would be nice if folks who worked on reorgs would do a lessons learned, and the US Government either kept or granted a consortium of public administration schools to keep, analyze and generate reports about them. Like the Wildfire Lessons Learned Center. I don’t know how many USG “lessons learned centers” there are…public and animal health responses? Rebuilding after emergencies? If states are the laboratories of democracy, then comparing state responses would be of interest.
All this reminds me of a post by Jennifer Pahlka this week, which is absolutely worth reading for Government Improvement types.. which I think should be all of us including Rs (if we’re spending the bucks, it should be worth it) Ds (let’s turn more things over to the government) and libertarians (I suppose if you’re going to get the government to do it…), but maybe not.
Outcomes Review for the National Forest Management Act ?(and FLPMA?)
To summarize:
The problem the Speaker’s office hopes to address is that California passes a lot of bills, but those bills aren’t necessarily solving the problems their authors are targeting. Between 2016 and 2022, for example, more than 100 bills to stimulate housing production were signed into California law, but even today permit numbers in the state have barely budged. This is the problem that sits at the heart of the Recoding America Fund’s work: government’s poor track record of delivering on policy intent.
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The problem the Speaker’s office hopes to address is that California passes a lot of bills, but those bills aren’t necessarily solving the problems their authors are targeting. Between 2016 and 2022, for example, more than 100 bills to stimulate housing production were signed into California law, but even today permit numbers in the state have barely budged. This is the problem that sits at the heart of the Recoding America Fund’s work: government’s poor track record of delivering on policy intent.
Outcomes Reviews are an experiment in closing that gap. They’re essentially a process that starts with a legislator announcing that they’re going to review the outcomes of a bill they previously championed. The member coordinates with the relevant policy committee and identifies stakeholders who’ll be part of the work. Then, over the course of a legislative year, the legislator and their staff, working with committee experts and direct stakeholders, hold a series of roundtables and hearings. They listen to the people actually affected by the law. They dig into what’s working, what’s not, where implementation has stalled, where unintended consequences have emerged. Finally, they announce what they’ve learned and what they’re doing about it. This might be a fix-it bill, an executive action request, or public coverage celebrating the law’s success—whatever the evidence suggests is needed. The work helps close the feedback loop between policy intent and real world outcomes.
Wouldn’t that be interesting to try for NFMA? And maybe, ask the question (instead of reorganizing the FS and BLM) in what ways should those two statutes be harmonized and or updated to meet the needs of the 21st Century? And not just lawyers talking about laws.. but practitioners and the public, who can be exasperated by the end result of how policy intent (whatever it was in 1976) is delivered.
Getting Rid of Travel Management Rule?
There is this op-ed in the Idaho Stateman.
Despite this long tradition of bipartisan support for sustainable off-road vehicle use, the Trump administration announced in September that the Forest Service intends to repeal the Travel Management Rule. Doing so would open the door to uncontrolled use of off-road vehicles on national forests — undoing decades of thoughtful policy designed to maintain access on designated trails, prevent erosion, water pollution and habitat destruction.
I couldn’t find the link to the announcement.. would someone please share? I know many TSW folks follow this closely.
https://www.reginfo.gov/public/do/eAgendaViewRule?pubId=202504&RIN=0596-AD70
This is the announcement in the OIRA Regulatory Agenda. The reason you cannot find it is because there is, very strangely, no link to it in the USDA Forest Service Reg Agenda Table of Contents. It was shared with me by someone who found it. I do not how they found it. I just know it exists.
Thanks, Paul! I don’t exactly understand it..
“This rule amendment would repeal the Forest Service’s travel management regulations at 36 CFR 212 to simplify the travel management planning process in response to legal challenges and to support more effective decision making at the local level, in accordance with Section 2 of Executive Order 14219, Ensuring Lawful Governance and Implementing the President’s “Department of Government Efficiency” Deregulatory Initiative .”
So they’re proposing a rule amendment to repeal a rule (???) but this isn’t an ANPR??? Help!
Note this line in the agenda entry:
“Agenda Stage of Rulemaking: Long-Term Actions”
This is OIRA-speak for “uhhhh … we’ll get back to you,” and explains why this entry doesn’t come up on the main list – that list includes only actions at the “prerule,” proposed, or final rule stage.
The RF for R1 let certain OHV groups know, informally, that the Travel Management Rule was under internal agency review back in May or June. I haven’t found any formal statements by the FS about this since then.
I’m all for putting the kibosh to the current Rule! It’s complex in the operations, having multiple differences between units, between Agencies, purposely lie to the public, all too often used as a stick against the motorized community and tweaks the noses of millions of people who thought they were a part of the process. Never sign a road closed but it must appear on a black and white map that contains multiple errors? Update maps when the mood strikes, instead of yearly (in the original rollout language). Violate NEPA anytime the FS wants to, to decommission another road/trail? Never, and I mean NEVER administer this pile of crap?
Now, if there was a push to actually coordinate with local governments and interact in a truthful manner with the public, I’d be all for it! Design the process to protect what really needs protection, etc.
I wonder whether some effort to harmonize BLM and FS “travel management” processes jointly on interspersed ownerships (involving States, Tribes, counties and private landowners) would be an interesting thing to try..
Absolutely! The pairing of both agencies travel regulations would certainly trigger scrutiny of the differences between them, and possibly the points of failure. There are echoes of the 2012 Planning Rule that have influenced Travel Plans over the past dozen years. I can see this effort triggering changes in the Forest Planning rules. But the devil lives in the administration in charge. There needs to be significant changes correcting policy that unnecessarily restricts the public, but by going too far, Republicans could make it harder to find peace in the long range, because a Democratic administration would tend to err once again by strangling recreation access. It would be nice to see an open minded approach to recreation and conservation, that better combines opposing policy than our current mess.
The Travel Management Rule repeal was announced via the OIRA Spring 2025 Unified Agenda of Regulatory and Deregulatory Actions: https://www.reginfo.gov/public/do/eAgendaViewRule?pubId=202504&RIN=0596-AD70
Thanks, Hilary!
Re: reorganization…”carefully thought out and carefully managed” are two concepts that did not jointly get fully invested in during my career experience. A lot of potentially effective ideas/strategies have been developed to meet the “thought out” concept, though when it came to the “managed” part, that usually fell short. Likely because leaders were already onto the next “carefully though out” venture. So, I view any grandiose scheme of reorganization with much skepticism.
I live in Oregon. 60%+ federal land. Policy and behind closed doors actions take place on the banks of the Atlantic Ocean in The Urban Strip Mall from Boston to the Capitol. Expand the Chief’s office and support staff to ALL being in Washington. Not in Virginia, nor Maryland nor West Virginia. District of Columbia. Why?
Get a complete divorce from the myth of PILT and “our decisions are for America” mentality. The wealthiest counties in the US surround D.C. Lobbists and corporate lawyers. Salaried Employee Service. Contractor and vendor offices. Pentagon? How many working there are pension drawing former, or retired military hustlers of the active duty who must activate congressional and administrative decisions and actions. USFS was designed to be paramilitary. Had a military like chain of command. Interior more like a disorganized conglomerate corporate structure with area potentates hustling their fiefdoms in land, indigenous peoples, resource extraction, parks, wildlife refuges, yada yada yada. And the leadership changes every four years So do the economies foolish enough to hitch a wagon to government administrative policies for making a living. Every Inspector General is permitted to form a “special ops” force to serve warrants. Over 70 IGS now HAVE ONE OR MORE. All SWAT and SERT trained, armed with automatic weapons. To herd whose cats? Even the USFS IG. Decades ago I was visiting the <$100,000 paperless USFS contracts and RFQs. Found USFS soliciting offers to furnish 36 Heckler and Koch NATO ammo automatic weapons. To defend whom from what? You don't read that stuff in the SO or in a presser from the RO. "Smoke 'em Bear"??? No need by then for "timber staff." Buggy whip specialists. So "cops" was the new two moonlight drives and a walk in the woods job.
Save the money. Take over a mothballed airbase in the D.C. area and have an "Octagon" with a section for each Region staffed to meet at the Chief's office in DC or just do it digitally. AI assist. Get ROs out of cities with city ideas. The disconnect with people and the USFS is at the GS 12 and higher level. I see none of the major urban cities that have text book management that meets any needs to be an example for all. Nothing will make any difference in how much fuel burns each year and where. The stand removal fires are happening, and in 30 years the whole of it can burn and return to the re-burns and new burns in emerging stands. For heaven's sake, never thin the regrowth. Waste of money. All it does is increase the crown size (flash fuel with high heat), and increase the intensity of crown fire in 40-70 ft reprod nicely spaced to grow crowns also gives ease of access to hot winds from existing fire to completely consume the needles and leaves of the leave trees.
It is obvious to me that there is NO interest in private capital put at risk to be dependent upon federal timber. No banking, insurance, bonding, logging equipment domestic manufacturing or labor. Timber is raw material for a product that is sold into the commodity markets. Mills don't set prices. Markets daily set the price. So purchasing timber sales, a process with cash deposits, to then build a road required at your costs, and then log when the land owning agency allows, into the market of Right Now, not the market of the day of the timber purchase. Add allowed interference and litigation, not against the purchasers, but against the federal agency that sold the timber, can keep the timber in abeyance for months or years. Schiff Show outcomes. Punitive third party litigation.
REIT owned timberlands cannot exist if not logging quarterly every year. Mills are now set up to cut dimension lumber for light construction. So it is 1.5" x 3.5", and 6", 8", 10" a full 2" wider than 5.5" nominally called "2×6". Rinse and repeat. That grade of softwood lumber is based on knot size. Young timber has knot size that gets smaller from the cambium to the heart. So start with 40 yr or less age timber, and knot size is favorable and that allows one pass x/y axis log positioning by AI decisions controlling the out come from band sawing omnidirectional systems that use quad bandsaws and chipping heads to make smooth sides and making pulp chips out of the waney round circumference of the log, leaving 90 degree angle square lumber and resaw flitches for the next quad band sawing in line. All that is based on a maximum log of 20"-24" diameter butt the long axis.
That is the determinant of earliest return on capital costs of site prep and planting trees for the fastest return on a long term investment. 2.5 to 3 clear cuts per century on each acre. Therein lies the limit on USFS burning and fire salvage. All the mills capable of cutting larger than 24" butt logs were gone except for a handful 30 years ago. No "old growth" timber supply to feed those mills today. just seed trees, uncertain property line trees from before GPS surveying. Hard to reach corners and hillsides from 40 or more years ago on private land removed today. All that and a paucity of fire dead trees along roads now danger trees. Depending on fire salvage is a waste of capital and opportunity. Saving mature timber to burn is the now acceptable management strategy of the US Government as directed by the coastal urban population majority.
NGOs of interminable litigation to "save" the world ever more and more are consuming the farm and woodlands with Apartment complexes and townhouses as "affordable housing" that will be a slum in 50 years. The slums razed to site antiquated, tech deficient manufacturing on cheap to develop land is a fool's errand. Cities grow upward at their core and outward to serve and house the work force and the ever growing dependency. The inner city rots between its core, in the multiple unit housing belts, and the suburb growth is in rings outward of those.
USFS was made, and is being made more so, irrelevant economically by PotUS Clinton by his directed 1993 destruction of the existing lumber industry using 100 year or longer harvest intervals. Then interminable warfare of Green NGOs with tax deductible trust puppy money vs. US Government mandates from Congress, the Administrative branch. All executive chefs with different menus. Too many cooks. And crapola broth.
The private sector was and will be hosed by the federal sector, and that is "capital at risk." Quarter billion dollar state of the art sawmills, engineered wood producers, all are unable to sell their production right now. Political players in legislative office deficit spend and the executive branch is cheering them on. So the Trillion dollar plus annual interest payments on debt buys what? Fire killed trees. Inadequate materials and manpower for "our common defense." Manipulated markets and consumer price gouging. The now "proverbial" Schiff Show. Nadler pants. Multi million dollar Covid fraud by elected and private sector players. Endless. Pograms. 7 billion plus mouths to feed world wide and places for them to SSS&S. My county and the one to the east share in feeding the hungry. East county has 344,000 population. Mine 90,000. SNAP recipients of the combined counties are 91,000. One out of every 5 residents cannot provide adequate food for them and their household. 60% of the land is federal. 10 billion board feet of dead timber since 2020 has gone unsalvaged on federal lands in my ;area of this state, Oregon. Double the amount of industrial timberland and small woodland owner logs produced annually from 6 million acres of industrial forests and 4 million acres of small woodlands from 1-4999 acres in ownerships statewide. Out of 28 million acres of forestland statewide. Lightning starts fires. The ones that become conflagrations arise out of roadless and wilderness areas. And then trespass on private lands and former federal land once managed to be logged and immediately reforested. Any federal logging is on land previously logged. And those lands were logged prior to 1996.
Federal fire consuming private assets has ZERO tort liability. Private land fire that burns federal land has UNLIMITED tort liability. Both the private victims and the federal land management agencies seek "deep pockets" to "make them whole." USFS is suing Pacific Power. The wolves of the plaintiffs bar are suing Pacific Power. 6 other electric provider utilities NOT PUC regulated (only "investor owned utilities are PUC or Energy Dept regulated) are owned collectively by user/customers: Co-ops, PUDs, Municipal and County owned are not sued because it is cannibalism in a manner. Eating your own. So "energized" power lines are responsible mostly when investor owned. Regulated electric service cannot be terminated. The regulated insurance industry can and is no longer offering fire insurance in areas of federal timberlands and basin and range lands. Burned once is risk and happenstance. Burned twice is a poor insurance business decision.
Well, my home electric bill is 152% of what is was before 2020, Labor Day fires, and the advent of Covid and rampant inflation, mass medical malpractice and political gamesmanship. With that went inflated fossil fuel costs, food costs, consumer goods costs. The USFS inability to sensibly manage the national resource which then drives economic instability locally has butchered the public trust and sorely wounded faith in capitalism and is fostering a rise in religious intolerance, anti government irrational hatred, and has produced a functionally illiterate class of emerging adults unable to find work despite being mined by academia of the family treasure to get a BS degree that is mostly a community college degree plus a GED. That is what an entering college freshman class brings to college and what they today can expect from the debt and false hopes is to find an apprenticeship and a trade if they do have communication skills.
USFS policies and administration are a meaningless exercise in personal dalliances in administrative jobs. If there was actual work being done, the perennially washboarded rock roads would see a grader more than once a Presidential term. Paved mainlines would have potholes patched. Roads are places of sunlight intervention, and a surface under which roots can grow, and water infiltrate, resulting in roadside trees growing twice a much as the trees one chain from the middle of the road. Logging the dead, the encroaching, also makes the POD product much more viable. The Chief's office is at a place to easily lobby the administration and the Congress to appropriate the money to preserve the access to suppress fires, keep roadside unplanned ignition potential smaller, and employ private capital in the forests working, and yet trained to use the operating equipment as a fuels management tool on POD-scape fires. The sale of the wood can add some PILT dollars to the county of origin. People could see the work done, see the results, and see back into the roadside forest beyond the weeds and brush, trees in that road prism micro site of accelerated vegetative growth. And that work could go on all year, up in elevation in summer and down in winter. Just logging to protect the capitalization of existing infrastructure, removing hazard trees, and give forest critters some feed at ground level, and an improved sight line for drivers, most of whom are recreating or administering the safety and conservation of the existing resources. Voters. Urban folk seeking the solace of self isolation for a day or two. Oh, and while at the Congressional appropriation trough, find the money to keep campgrounds open, the pit toilets pumped, earlier in the year and after Labor Day to annual mean first snow fall time in the warming climate. The furries need the forests, too. Fall hunters, also. And all who look forward to fall weather, cooling, comfort of a wood stove in an improved campground.
Common sense does have a place in the conversation. If I am too wordy, it is because I can and do read but am unable to "write code." No longer remember morse code from my 1950s Boy Scout days.
The “Department of Natural Resources” idea has been around… and around.
I agree with others who urge skepticism. Secretary Babbitt’s well-intended National Biological Survey idea for reorganization within Interior ran into a buzz-saw and just complicated the USGS’s life..
I think the chances of the FS being moved to Interior are sub-microscopic. Still, speaking out is important.
I haven’t seen an announcement but our Forest Supervisor told our trails organization several months ago that it had just been rescinded and would be reworked in some fashion. I did a web search at the time and came up empty. Haven’t looked since.
I’ll be looking forward to seeing what happens with the travel management rule repeal. Not really enough information to go on about that yet. I think it’s obvious they can’t just do a straight repeal but need something to replace it. Hopefully there’s a return to the old open unless designated closed rule, with clear criteria for what justifies closure.
It would be huge progress if travel planners were simply required to balance recreation benefits with environmental impacts, as there’s currently no requirement in either agency’s travel management rules to consider recreational benefits at all. They usually still do in some fashion, but the only mandatory criteria are all about mitigating impacts with no acknowledgement of the benefits roads bring.
Patrick, While I’m mostly a non-motorized recreational user – I use motors to get to hiking, skiing and firewood gathering areas – I’m a recreation multiple use advocate. While working on the Rio Grande NF, I was a strong voice against the many internally who wanted to remove the motorized status of the Lost Trail – West Lost Trail – Pole Creek loop during development of the travel management plan in the 1990s. I know you know where that is. And I wrote the letter signed by the Forest Supervisor against including that area in the proposed Handies Peak Wilderness.
All that said, I have to disagree with you on returning to the old open unless designated closed rule. It’s impossible to keep road/trail closed signs posted as they are removed almost as fast as they are put up. I remember seeing a closed road with the sign removed from the post. Some wildflowers caught my attention below the main road across from the closed road and when I climbed down the hill to photograph them I found three road closed signs lying on the ground. There are many challenges with the current system, but open unless designated closed was much more challenging.
Yes I’m very familiar with that area, though I’ve only been on the full size Jeep trails in there not the 50 inch and moto trails. I appreciate your work keeping those trails open.
I’m not quite sure what the best solution is long term for how to manage open/closed. You’re certainly right that signs alone aren’t enough, since those are too easily stolen or vandalized. For an open unless clearly closed regime to work, it would probably require the FS to put more substantial resources into implementing closures on the ground, like installing sturdy gates or hardened barriers at defensible chokepoints where people can’t just drive around. From my own observations, those kinds of closures tend to be respected, while ones with just a sign often are not.
But on the other hand, when roads are only ‘closed’ by omitting them from the MVUM with no signage on the ground, those closures are rarely respected at all because people either don’t know about them or have a hard time telling an intentional closure from a mere mapping error. That’s particularly the case when the FS decides to cut roads short and close them at an arbitrary point, so the MVUM shows the road ending when it obviously continues on the ground. Given how many blatant mapping errors are on the MVUM showing roads in the wrong places, it’s impossible to know if the FS intended the road to end there or if they just mis-mapped it.
At any rate, whether its closed unless designated or open unless closed, I think what’s really needed is to reverse the paradigm that roads are first and foremost an environmental impact to be mitigated, rather than a recreational resource to be valued. If the Forest Service wasn’t constantly trying to close roads with high recreational demand and a long history of public use, enforcement wouldn’t be that big of a concern. What we really need is a travel management regime that puts the burden of proof on the Forest Service to prove that road closures are necessary and impacts cannot be mitigated in other ways, rather than making all roads presumptively subject to closure unless some overriding purpose and need can be shown, which basically puts motorized users in the position of having to individually justify the existence of every road in the Forest every time a new travel plan is made.
Most, but not all, of the motorized and non-motorized roads and trails closed on the Rio Grande National Forest over the last thirty years has been done due to pressure from the Regional Office, as instructed by the Washington Office, to reduce inventory needing maintenance. Additionally, some are closed, sometimes only seasonally, due to agreements with Colorado Parks and Wildlife. Budgets have not kept up with maintenance needs. Volunteer groups have helped to somewhat fill the gap, but not enough.
I’m on the board of a local water conservation organization and have broached the idea of securing funds to help maintain some of the level 2 roads in this area that have the greatest erosion issues. Other board members and the forest are interested in pursuing the idea, but the group doesn’t have the capacity to follow through at this moment. Hopefully, we can soon.
The RGNF tries to sign closed tracks, but as I mentioned, those signs often have a short life. When possible (budgeted), gates are put up but often locks are cut. Like any recreation group, most motorized users abide by the regulations but there are some who don’t.
I think recreational travel on national forests can be handled somewhat effectively, but only if it is adequately funded. Pretty much like all the programs managed by national forests.
I would hope there is a group working on a replacement that improves the current situation, identifies the problems, and attempts to make things work better and more transparently for everyone. For one thing we have technologies that we didn’t have when the rules was promulgated that might help with maps, and possibly enforcement. But maybe that’s too logical…
I suppose they could do a FACA committee but there’s a great deal of paperwork. Maybe some NGO should bring folks together and make recommendations? Maybe they are already?
I know the Blue Ribbon Coalition has been doing a lot of lobbying on this issue, though I don’t know exactly what they are proposing as a replacement to the travel management rule. This definitely needs a lot more discussion to turn into a concrete proposal.