Jon raised an interesting question from the management perspective..
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)?
It reminds me a bit of some media outlets. Trump Admin proposes something. It must be bad. Even if a previous D Admin proposed the same thing. If that is pointed out by someone, there are a couple of responses, they don’t really mean to do it If the Admin does it, they won’t do it right. Then the media outlet finds people who will prognosticate about all the things that could possibly go wrong.
If we put the partisan lens aside and just think about management, I’m sure every organization faces (some of ) the same challenges. If we were rational (ha!) we might ask the same question about the directives as we might ask about the current state of NFMA planning… what good does it do? to whom? And ask a variety of folks with direct experience, inside and outside the agency, to make suggestions for improvement. After all, we have 14 years or so of revisions under our belt, and they aren’t happening exactly as projected in the regulation. Sometimes I wonder whether partisan views are getting in the way of a reasoned approach to improving the way the US government works.
Some directives serve a purpose both to folks inside and outside, as a compendium of current info on how the agency does things. Like current CEs in the NEPA directives for example. I had to go outside the FS to find a spreadsheet with them.. so this is an example of “keeping important info in a format that is updated as needed.”
There are “required ways to do things based on statute and regulations and national interpretations” which is likely where the Timber Manual fits in.
Again, we get to “both things are true”: (1) the folks on the ground know best, as the Chief says and
(2) without any sideboards from headquarters, or shared learning, there can be much reinventing the wheel, at the taxpayers’ expense. (I think the Frenchian effort to centralize some aspects of plan revisions was in response to the forest’s “once in a career” amount of learning and creativity.)
Psychologically, I have seen forests and districts unwilling to change their practices when other forests and districts are more successful with a different approach. Stodginess, or a careful internal or external political (small p) sensibility? “Not invented here” or “line office fiefdom” or “real world differences at that unit”? Who knows?
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Jon asked “Did someone (like the public) say that more consistency (not less) would be a good thing?”. I only have two data points… yes- wildland firefighters think more consistency would be a good thing. Also the Service First effort (based on my own experience, at least in SW Colorado) showed the public preferred some consistency between the FS and the BLM.
There are legitimate disagreements about how to do things.. for example, I think selecting planting stock on the basis of computer models of future climates is silly. Others think differently. Is diversity of practices (the results of success won’t be known for 50 years at least) a good thing or a bad thing?
So I think that there are different threads here to untangle…
1. Consistent availability of key information on data important to the public (like recreation sites, fuels accomplishments and so on- the People’s Database). Probably consistency with the BLM would be handy. But this is not directive.
I remember when the BLM and the FS were doing expensive and to me, not all that different kinds of “assessments” on neighboring pieces of land in Colorado. Most of the topics seemed to be the same.. but no one could say “hey, why don’t they draw a line and do it together?” We did try to do an RMP and Forest Plan together and that did not founder on the shoals of regulations, but it seemed, on lack of support from Regional and State leadership, which might have traced back to perceived losing some degree of control. It’s not easy stuff.
2. Conscious discussion of what needs to be consistent direction and what doesn’t and why (statutes, regulation interpretation).
3. Within the regulatory framework, discussions of best practices (perhaps this should be organized as a learning discussion online rather than an agreed upon document).
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But back to Jon’s “deregulation” and “marching orders” aspect.. freeing up locals, it seems to me would work both ways. Patrick has pointed out that the predilections of some line officers against OHVs seems to influence their decisions. If we assume that most FS employees are more allied with the D-ish inclinations (which may or may not be contested, but I’m fairly certain there is evidence) perhaps this would ultimately free them to do more bias-wielding in the future?
My main data point for consistency was the 2012 Planning Rule, where inconsistency in management approaches across national forest boundaries was a major concern we heard from the public. A lot of this was in the context of whether forest supervisors or regional foresters should have the decision authority for forest plan decisions (forest supervisors winning, but with a supposed commitment to WO oversight for consistency). Centralized planning services would help address this, though I agree that efficiency may have been the point. In general I did not see a lot of internal support for telling forest supervisors what to do (throughout my career).
As for partisanship, I’ve just come to believe that the Trump Administration really does want to break things, with not a a lot of thought about leaving something that is able to function competently. Maybe the traditional Forest Service relative insulation from politics will again buffer them, but these are not normal times. I do think it’s interesting that they are starting with a regulation about directives (as opposed to just plunging into changing the directives).
As for local bias, there’s that, but there’s also performance targets, which I think usually win out.