This document has come to my attention, which I believe to be the content analysis of the public comment on USDA Reorganization. It’s separated out by the source of comment, employees, retirees, form letter campaigns, and a variety of others. It’s quite long and does talk about other parts of USDA than the Forest Service. If I were the FS or the USDA, I would go back and have human beings with experience writing and editing the English language do the analysis, or at least make this one comprehensible. I can’t make heads or tails of some of it, and I my guess is that it was done by AI. There is much of interest, so feel free to comment on other sections
Category: United States Forest Service (USFS)
This section synthesizes insights from 6,292 comments. While 60% of comments express concern, they also provide constructive feedback, with 17% offering positive sentiments and 7% neutral.
Key Themes USFS
Regional Offices and Local Expertise: Stakeholders widely view regional offices as essential for effective, localized decision-making. 34% of comments referred to the elimination of regional offices or loss of regional leadership, with 25% citing specific impacts on environmental planning. Concerns that “The proposal’s elimination of the nine regional Forest Service offices, six in the western U.S., where a majority of the national forests are, would concentrate decision-making far away from landscapes that are diverse and face region-specific pressures (e.g. fire risk, invasive species, drought).” This perspective underscores the risk of detaching decision-making from the unique environmental and social complexities of each region.
As a former RO employee in “environmental planning”.. I don’t actually remember the RO doing much decision-making. The RF signed off on Forest plans (at the time).. we did a Regional lynx amendment (not sure who signed it). It’s not that I disagree with the idea, it’s just one of those content analysis things where you don’t really know if the commenters were responding to something specific, or they had a different idea of how decisions are currently made.
Ecological and Species Integrity: A significant theme is the imperative to safeguard migratory species and their habitats. 28% of comments referenced ecological impacts, with 15% specifically citing the 2012 planning rule. The reminder that “Over 60% of migratory species across the United States depend on Forest Service lands” underscores the critical role of the USFS in biodiversity conservation. Stakeholders express concerns that the loss of regional oversight could create gaps in protecting these vital resources, particularly in ecologically rich areas like the Pacific Northwest, preserving our natural heritage.
What is this new “migratory species” thing (we saw that about prescribed fire)? What does reorg have to do with the Planning Rule? Where does the “over 60%” number come from? Maybe in this concern somewhere is the idea that forest plans need to be harmonized so that species that cross boundaries are adequately provided for. But so far just having an RO doesn’t necessarily do this. Then conceivably you would want to harmonize with RMPs as well..
Sustained Funding and Resource Allocation: Consistent advocacy for “robust and sustained funding for this vital agency to maintain its ecological and social missions” reflects a strong understanding that financial stability is foundational to the USFS’s capacity to deliver on its mandates, both environmental and community-focused, securing our long-term success. 22% of comments directly addressed funding concerns, with 18% tied to the International Program (IPT) of the Forest Service.
So USDA should ask Congress for more bucks. OK then. I think the reorg folks would say they want more money to get to the field, given what Congress appropriates. IP folks must have made an impression.
Mineral and Mining Personnel Efficiency: Comments, particularly from Oregon and the Pacific Northwest, point to a desire for improved efficiency in mineral management staff. 8% of comments criticized the inefficiency of current minerals personnel in managing mineral resources.
There must be folks out there with a ready keyboard and an axe to grind.. or whatever the mining equivalent is.
Public Trust and Transparency: Perhaps the most emotionally charged feedback relates to the perceived lack of public consultation and transparency throughout the reorganization process.
This is one of those situations that reminds me of the questions for the Old Growth.. maybe more specific questions would have helped, like “what kind of outreach would you like to see?”
Preserving Regional Trails and Public Access: Among the most frequently voiced concerns is the potential reduction of Regional Trails Programs. Stakeholders fear that the proposed reorganization could inadvertently erode vital recreational access and diminish significant economic benefits derived from these extensive trail networks.
I don’t know what this is..???
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Empower Regional Hubs for Dispersing Authority: Leverage regional hubs or offices to effectively distribute decision-making authorities.
What does this even mean? I envision an authority dispenser similar to a paper towel dispenser.
Preserve Local Offices: Prioritize the preservation and strategic enhancement of local USFS offices and programs. Maintaining and strategically investing in these local structures and programs, coupled with transparent governance, is essential for sustaining localized expertise, fostering landscape resilience, bolstering operational efficiency, and ultimately strengthening public confidence and the USFS’s vital local impact.
I think this is what was intended, but it never hurts to hear it from public comment.
Ensure Sustained Funding for Conservation and Operations: Ensure that the reorganization will not result in additional layoffs or loss of field positions critical to land management and recreation. Conduct and share a clear staffing impact analysis for any office relocation or closure.
“Don’t lose field people” makes sense but again, that’s not necessarily “sustained funding.”
Improve Communication and Transparency: Engaging stakeholders throughout the reorganization process. Incorporate robust public input from gateway communities, recreation users, and conservation partners before finalizing changes.”
So I worked in the RPA Program, and I know laundry lists.. this privileges some above others. Didn’t need to specify those.
Align Headquarters Staff to Regional Hubs: Assign Washington, D.C.-based staff to regional hubs aims to maintain operational efficiency and strengthen regional expertise.
As stated, this isn’t good English. Assign.. aims. This is really odd. Assigning is not aligning. Does it mean “assign WO staff to Regions?” That’s a “top recommendation”?
Optimize Mineral Personnel Efficiency: Conduct a comprehensive review of minerals management staff and associated responsibilities to enhance efficiency and effectiveness.
I’d say call up the commenters and see what their specific issue is.. I would bet the Minerals folks already know.
Stop the 2012 Planning Rule: Clarifying the 2012 Planning Rule is widely perceived as crucial for ensuring consistent and effective forest management standards across the USFS.
What needs to be clarified? Stopping and clarifying are not the same thing.
I think this is driven by non profit environmental groups who for years had been given a cozy reception at Regional Offices any time they did not like decisions made at forest level, or wanted to force Forest Sups to make the similar decisions on zone or regional issues. It was a counter productive waste of time when regional staff would pander to them, try to twist the arms of Forest staff only to ultimately be told to let the Forests do their jobs and make local decisions. I believe many Forest level employees saw Regional Offices as bloated high graded inefficient controlling and strongly biased toward protection and against multiple use. I say good riddance to that system.
My guess is the ‘regional trails’ is actually referring to National Scenic and Historic Trails. I know there were quite a few letters submitted that were specifically focused on potential impacts to NSHTs and the fact that the Trail Administrators who oversee those trails are regional office employees. That’s just a guess given all the letters I saw about NSHTs, but it could be referring to trails more generally.
OK, thanks, that makes sense. I always knew them as NSHTs.
“As a former RO employee in “environmental planning”.. I don’t actually remember the RO doing much decision-making.”
The implied innocence of RO leaves me dumbfounded. When it comes to resource protections – which is the source of NEPA dilation in management actions – RO culpability is a given. Generally, you want to rely on the RO but disconnectedness keeps you from making that call for ‘support’
“Preserving Regional Trails and Public Access: Among the most frequently voiced concerns is the potential reduction of Regional Trails Programs. Stakeholders fear that the proposed reorganization could inadvertently erode vital recreational access and diminish significant economic benefits derived from these extensive trail networks.
I don’t know what this is..???”
Spoken like an RO employee…
Because I knew them as National Scenic and Historic Trails. and because words like “regional” and “national” have different meanings to me..
As a recent Regional Office retiree who spent 10 years in an RO, I’ve thought some about what if ROs go away…during my 40 year career, the RO was always a place for expertise that was not available at the district or forest level. But given the lack of experience and expertise at the district and forest level due to lots of retirements in the last 10 years and relatively new and inexperienced people at all levels of the agency, the role of many in the RO in mentoring and training new employees is very important. And many of the remaining RO employees with that experience and expertise have moved to the WO in the last 3-5 years. For the RO to go away now, district and forests would need to nurture and culture expertise, and while that is more feasible at the forest level than the district level (where things are more production-focused), it is still a big lift. And most District Rangers have become very external-focused instead of internal-focused (and were hired for their ability to coordinate externally).
Thanks, A. I would think that ACES could help provide mentoring and backup support until the new folks get more experience.
It seems like during the hiring spree there may have been more of a focus on hiring folks with “partnering” and “coordination” skills rather than “doing” skills- whether intentional or not. And with the experts leaving due to VERA and retirements that could yield a serious gap in technical skills.
ACES is a mixed bag. The critical thing here is to allow employees the time to develop the expertise by attending training/reading the FS manual/reading the Forest Plan, etc. If you’re on a district that gets snowed out of the woods, that may not be too hard to do. But right now folks are being pressured to produce, not learn.
A.. you’ve raised a good point, I’ll start a broader discussion about this.