Posts from Peter Williams always combine his many years of experience and thoughtfulness, so thanks to him for taking on these topics.
*******************
I’m going to pick up on two discussion threads that have some overlap. The first is the discussion of scoping and where it comes from. The other is the discussion of what to standardize in the FS. I’m going to look at these through a decision process lens.
About 12 years ago I ran what was then called the US Institute for Environmental Conflict Resolution for a few years. Our mission was all about supporting Sect 102 of NEPA. That was after spending many years with USFS focused on collaborative planning.
During my time with USFS, I worked on and with Decision Protocol in the late 1990’s. It integrated decision-making state of the knowledge and tools, partly to address the idea that NEPA is USFS’s default decision model (it isn’t). It resulted in an iterative five-cycle process to move from recognizing a problem, diagnosing it, designing a response, acting, and assessing. Later, I worked on what was called The Safety Journey in the late 2000’s, an effort to reduce serious incidents, including deaths, by improving decisions and accountability. I helped with rolling out some of the related tools while serving as an Acting Forest Supervisor in about 2012 or so.
Both of those efforts were really about decision making writ large (as opposed to framing decisions only through the lens of NEPA compliance, whether EA, EIS, or even, in some cases, Categorical Exclusions (CEs) like Anon mentions when talking about scoping). I also taught a graduate course on NEPA in the late 1990’s while working on my eventual PhD related to collaboration and decision making.
Scoping, as well as public participation or collaboration, were front and center to all of this. So was the question of how much process structure is too much and how little is not enough.
Returning to the scoping discussion, something not mentioned yet is that CEQ put out guidance on scoping in 1981 that is consistent with the only use of the term “scope” I find in the 1969 NEPA legislation. The reference in the legislation is to the “…scope, objectivity, and content of the entire statement…” referring to what we now know as an Environmental Impact Statement. It’s in Sec. 102(D). “Scope” originally was about the scope of the document, the scope of the decision, a concept borrowed from project management and dating to pre-WWII. The term scoping, then, refers to the process or processes of determining those scopes, much as is done for project management in so many other circumstances. Is it “in scope” or “out of scope”?
Regarding standardizing process and procedure, at least from a decision process perspective, it seems useful to distinguish between consistent processes that are *rigid* and ones that are *flexible*.
It is possible, for example, for a consistent *design* process to result in somewhat different planning processes tailored to different needs or circumstances. Different Regions or different Forests within the same Region might use a consistent design process to design a tailored collaborative planning process that meets the relevant needs of the Unit, partners, and interested individuals or organizations. That’s an example of a flexible process. Notice how the NEPA-related concept of tiering fits here. A consistent design process can tier down to planning processes that are appropriately different because they meet different needs.
If done well, projects that are trickier (like coyote, the trickster) can be given more time and attention while less tricky ones can go through faster. That’s the idea of a consistent, yet flexible process that can adjust to circumstances and needs. I often described this as using familiar tools in unfamiliar or varied ways driven by circumstances. A skilled carpenter, for example, can use a hammer in creative ways when faced with challenges the rest of us might just turn into a mess.
In a sense, scoping as a process becomes a way to validate or verify the “trickiness”, an idea that can have aspects like public interest, scientific complexity, or political sensitivity, among others. CEQ, in 1981, produced a reference document called “40 Most Asked Questions” that includes a question about using scoping prior to a Notice of Intent (NOI), pointing out that scoping after an NOI is only a minimal requirement and that scoping is a useful tool for any number of challenges.
Scoping done well also is a way to engage with interested parties early on so they can better understand what’s being considered and why (like scoping a purpose and need first, and only latter doing a more formal scoping to address significance, effects, and proposed actions or alternatives). Done well, scoping can reduce some concerns while identifying the ones that really deserve attention, that drive an understanding of likely effects or consequences. This seems to be what NEPA means by an interdisciplinary approach that ensures integrated use of natural and social sciences as well as the environmental design arts (Sec. 102(A)).
All this is to say, in answer to the question about where scoping comes from, it has deep roots in various management and planning fields, it has limited appearance in the actual NEPA legislation and much more in CEQ and agency regulations, and agency culture shapes its use even today. Regarding standardization, it seems helpful to recognize a difference between standardizing a process such that it becomes brittle and using a standard set of concepts to design a locally-relevant, risk-tolerant process.