This effort involves restructuring the Directives System and clarifying the purposes of its two components, the Forest Service Manual and Handbooks. We are preparing to take the first step—issuing a proposed rule—this spring.
I’ll tell one story, and I’m sure you have your own which we would like to hear about directives. In the early 2000s, I was working on developing the Limited Timber Harvest CE with my the EMC Deputy, Pam Gardiner. The process was basically we worked on stuff, CEQ asked questions and we worked on more stuff in return, for months, until Mark Rey (our undersecretary) had a chat with Jim Connaughton, at that time head of CEQ.
Pam and I convinced the nice attorneys at CEQ that certain bad things wouldn’t happen because of requirements in the FS Manual and Handbook in timber management or whatever it was called at the time. We were quite happy until we returned to the Yates Building, and the timber folks told us that they didn’t actually follow those requirements (implying that we should have known). Point being their existence did not, in this case, contribute to clear inter-staff communication.
On the other hand, the NEPA handbook has all the relevant information a person would need to find out what the FS is required to do. I used it all the time when I worked in NEPA, and it’s also helpful to externals and even me here at TSW to know that the info is in one place.
My conclusion is that some roundups of info are useful and others are not so much. In the Tree Improvement Program in Region 6, we had Regional Tree Improvement Papers that gave people advice on best practices, but didn’t have requirements and could be easily updated. So there are other ways to standardize advice, compared to requirements.
What has been your experience with the Manual and Handbook? And what would you like to see changed?
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Here’s the Chief on this:
For too long, the Forest Service has been bogged down by excessive processes that hamper innovation. I want every employee to focus on actions that roll back this red tape. Doing so ensures critical projects are easier and faster to accomplish. I believe that the people closest to the ground know the forest best, and we should listen to what they have to say.
As I stated in my FY26 priorities, deregulation is a top priority for our agency. Most would agree that our directives are overly complicated, lengthy and outdated. At my direction, the Forest Service Policy Office has developed and begun implementing a “Directives Modernization” strategy. This strategy will streamline and simplify our directives and return discretion to decision-makers in the field.
This effort involves restructuring the Directives System and clarifying the purposes of its two components, the Forest Service Manual and Handbooks. We are preparing to take the first step—issuing a proposed rule—this spring.
Through this rulemaking we propose to redefine the nature of the Forest Service Manual and Handbooks. All mandatory directions will be contained in the manual. These requirements will be reduced to the minimum necessary to ensure we comply with the law, keep people safe and manage taxpayer dollars responsibly.
Once the rule is finalized, handbooks will contain only non-binding advice to help employees get their jobs done—no more inflexible mandates or prescriptive procedures. The new handbooks will support employees who are new to the agency, to their role or to a place while empowering those with more experience to make decisions based on their hard-earned knowledge and expertise.
Additionally, we will rescind most regional, station and unit-level directive supplements to provide a more consistent set of expectations for agency employees—and greater predictability for our partners, visitors and customers—across all Forest Service units.
We aim to complete this part of the strategy by the end of the current fiscal year. We also plan to revise national directives to align with the pending agency reorganization. That revision will ensure authorities are delegated appropriately.
Rightsizing our directive system is a substantial undertaking that will require input from a range of stakeholders inside and outside the agency. The Policy Office will lead this effort and work collaboratively with programs to make the necessary directives changes. Public and tribal notice and comment opportunities will be provided for the upcoming rulemaking and for each subsequent step required by law. We look forward to your engagement and feedback.
It sounds like employees and stakeholders will have time to think about this.. we can start with some discussion here.
I retired back in 2019. Before I did, I was the pesticide-use specialist for R5. As part of my role in that position, I was responsible for updating the R5 supplemental handbook to the national pesticide use and coordination handbook. One of the main reasons we had a R5 supplement was because of the fact that we relied on California pesticide applicator licensing to keep our employees trained and licensed. We had also a long-standing agreement with the state of California that we would follow all state pesticide regulations in our FS pesticide applications. We also agreed to only use those pesticides that were registered by the state of California on NFS lands in California.
I would imagine that elsewhere in the FS, there are similar agreements with other states, not just in pesticide management but other disciplines (especially where state licensing of professionals exists that overlaps with USFS job titles). The chief’s call to largely eliminate all regional-level guidance in the directives could end up throwing out these agreements. I wonder how the process will identify where regional directives are in place for good reasons.
What I saw was the evolution of Handbook and Manual direction from useful/required to “meh”. Back in the late 1970’s, Directive training was a requirement for advancement from grunt to forester status. I thought they did a great job of aligning the knowledge of the “how”, from the top down. College was a great preparer but the government does things their own special way!
Back when Good Neighbor first came out ((Colorado and Oregon were demonstration States), in believe in 2001, I thought this was the best thing since sliced bread! Hayman fire in Colorado in 2002, eroded even more trust in the FS handling of things, since the fire was started by a FS employee. The fire was the largest in history, at that time, and devastated whole communities, burned over 400 homes, etc. Good Neighbor (Jim Hubbard was CO State Forester at the time) allowed the relationship to build trust to actual treatment of Forest lands, with the State doing the cover (work). One added benefit was the States ability to use private lands for product removal, alleviating the need for the long process of acquiring FS right-of-way, allowing treatment of landlocked WUI acres.
Problem was, as everyone from the Congress on down was yelling go-go-go, our Directives were caught flat footed! I had many a butt-chewings, from mainly TSAC over accountability of federal property (logs). To say we made it up as we went probably didn’t do justice as to how far out there we were operating, outside FS guidance. Eventually, they (TSAC) caught on. 🤣🤣
After that, say 2010 and on, new hires basically had no emphasis on learning Directives, and by that time the FS had become more of a social experiment in accepting behavior uncharastic with our original mission. We kept the required hard copies, and updated direction but even those updates became fewer and farther between.. I doubt new hires now could even locate the Directives system.
Good, maybe this will force specialists to recognize they recommend not decide.
See website.
Just for the record, agency directives are not enforceable against the agency in court, so this is an internal management problem. They can enforce what they want to, or not.
Did someone (like the public) say that more consistency (not less) would be a good thing? Does anyone think that this is really about “rightsizing,” and not a partisan deregulation effort (getting rid of the things that get in the way of their marching orders)?
This will be fun. They’ve been trying to change FSM 2670 (ESA and sensitive species) since I was working on the 2012 Planning Rule. (And there are things in the Planning Rule that require Directives – hey maybe this will be a chance to fix the mistake they made with timber volume – https://forestpolicypub.com/2022/03/18/timber-sustained-yield-requirements-for-forest-plans/. Right.)
I speak as a former “enforcer” of manual and handbook direction. On the timber sale administration and preparation side of the house, the directives provide a handy reference (if one chooses to read it) to meet the intent of legislation and the implementing CFR’s. As Jim has pointed out there has been less reliance on following the directives, particularly from Line Officers and Directors. We have been told if we are not breaking laws, then the policy and handbook direction was just that, merely a guide. In the push to streamline the production of timber sales, there has been increased pressure to not use tree marking paint, reduce timber cruising standards, skip the appraisal process and shorten advertisement periods. I reminded Forest Staff numerous times that an appraisal and advertisement periods are prescribed in the CFR’s. Nevertheless, Forests continued to go their own way, with tacit approval from Directors and DRF’s; this all done in the name of meeting targets.
The training of Sale Administrators, Forest Service Representatives and Contracting Officers includes training in the same manner as Jim describes in the 1970’s. In fact, the training is better than I had when I started my career. The current Timber Sale Contract relies heavily on the appraisal as a basis for making adjustments to rates for environmental, catastrophic or market changes. I see the Forest Service drifting in uncharted waters, opening up to more litigation and claims if we continue to follow what some are proposing. This drift in direction is causing much scratching of heads among timber sale contracting officers, as well as the remaining Washington Office timber staff.
Thanks for the update, Brad! How does it work when partners or NGO’s are running the contracts? I’m sure many of us would like to know which parts the FS is keeping in-house and how the manual and directives are or aren’t used by them.
The requirements in the stewardship agreement mirror the Timber Sale Contract for the most part, with the exception of those provisions that deal with changed conditions. So as far as implementation is concerned there is not al whole lot of difference. We typically have better results when the Partner hires an ex-Forest Service sale administrator. Forest Service retains the authority for final acceptance.
Whereas the timber sale contract has provisions to make adjustments for changed conditions, the Partners contracts do not, which has presented some concerns to industry. The Partner does not have the ability to obligate Forest Service dollars for paying claims as an example.
The procurement process is wholly under the purview of the Partner and bid protests (which I have seen) are resolved through their internal processes, as opposed to the Forest Service bid protests which are resolved by the GAO.