Sharon

“The Dog in the Manger” School of Government Improvement and the Need For Bipartisan Work and Structures

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This story (thanks to Nick Smith) on USDA reorganization plans being litigated, plus looking into the Clinton-era Reinventing Government efforts which identified many of the same issues and concerns and acted upon them, without apparent litigation, makes me think that the current partisanization of everything has led to a “Dog in the Manger” approach to government improvement. “We don’t want to fix these things, but we don’t want you to either, and we will bark at you if you try.”

Friedman’s Law: No Public Policy, or Government Program is Improved or Clarified By Becoming a Partisan Issue. As I used to say about a project on the Rio Grande “reasonable access for unreasonable people,” reason tends to go out the window once tribal loyalties enter the picture.

I’ve told this story before, but there are new people here, so..  As a training assignment, I worked on Representative Carrie Meek’s staff  (D-17th District Florida, first African American  elected to Congress in Florida since Reconstruction) in the House. Being a small staff, I did science, women’s issues, the biological side of medicine, and the environment.   As the rep to the Democratic Environmental Caucus, I suggested that we work with the R’s on improvements to ESA. The head staff person on the Caucus told me “we don’t want to do that because it’s more important to attack R’s that want to change it.” OK, then.

Isn’t it reasonable that organizations would  figure out key measures, monitor those, and try to improve. Wildfire folks tend to be more structured and upfront about all this.  Like I often say, we get more lessons-learned from the Fire people on an ATV rollover than we got for Covid response, or closer to home, the NWFP or the 2012 Planning Rule.  Perhaps it’s because some can argue that there is nothing wrong, so why improve? But we know that some people think that there is something wrong, so why ignore them (or not even have a process to listen to them?)

Let’s use Forest Service policies as an example.  Some people have seen problems with the mapping of 2001 Roadless, with forest planning implementation, with travel management mapping and implementation, or a $740 million deficit?

Here’s how it seems to go:

1. Everything is fine.

2. Some people think things are not fine, but we can ignore them, or don’t have processes in place to listen to them.

3. The people who think things are not fine have spoken with politicians who agree with them.

4. The politicians are doing something or are asking the organization to change.

5.a. They are the wrong politicians (from the other party) so we can focus on how bad they are and they want to destroy everything. And/or

b. Ok, so there might be a problem, but they are going about fixing it the wrong way, because their intention is really bad and they have bad ideas to boot.

And never have a discussion directly addressing the concerns and potential alternative approaches.

6. When we get back in charge, we continue to ignore the problems.  Hurray!

This can work with 1-6 being worked by either party for different issues, but right now it seems to D’s and their allies focused on not changing organizational structures.

It seem to me that the fact is that folks will always disagree, about what should be decided, what scale it should be decided at, and what the decisions should be. In Spencer Cox’s book, he says that he thinks the best way to get good, long-lasting decisions is through the legislative process, because people with different views have to interact directly with each other.  Of course in a lopsided legislature, they don’t have to. And they might be more interested in performative displays that look good on social media, decrying the badness of the other party, or working on their elections rather than sitting down to work things out.

In my experience, what might  be helpful is to have standing groups with representatives of various interests to review, at regular intervals,  implementation of regulations or processes.  I would say FACA committees, but these tend to be overly regulated and hard to keep going due to all the paperwork.  Plus the current Admin often wants to put its thumb on the scale (or more than a thumb, in some cases).  Most of the groups that get started to work on something are disbanded by the time the flaws start showing, and the agency might not have the energy or political oomph to argue for fixing the problems (and factions within the agencies might not agree on what the problems are).   On the other hand, to be within an organization and know that something isn’t working often runs into what some partners call “antibodies to change.”

I would propose that in the same way that the Colorado legislature selected interests for the State Roadless Taskforce, that the federal legislature could select interests and require an agency to set up a review taskforce to examine implementation at 10 year intervals.  It would include open public listening sessions and documentation, and identify needs for change, both for agencies, partners and Congress. Because courts work off statutes and sometimes case law can develop over time that is not great for anyone.

For those who are interested in improving government implementation..check out Recoding America by Jennifer Pahlka, this is a Google AI summary..

  • Policy vs. Implementation: The book argues that government fails when lawmakers separate high-level policy from the messy details of how it is actually carried out. [1, 2]
  • Industrial-Era Culture: Government relies on rigid, outdated systems from the industrial age that make public services slow and cumbersome. [1, 2]
  • Focus on Outcomes: Instead of just buying new technology or adding more money, the government needs to change its operational culture to focus on real human outcomes. [1]
  • Test and Learn: Agencies should use flexible feedback loops and test-and-learn approaches rather than sticking to decades-long, top-down plans that fail in practice. [1]

Pahlka and Greenway at The Niskanen Center developed this thought paper for those who are interested in the broader topic of improving state capacity.

Rebuilding our state capacity — the how of our government — is an arduous task that requires a stomach for learning and fixing the rules and culture of the bureaucracy. But make no mistake: whether or not we do it is not a technocratic choice. It’s a political choice — a leadership choice. Previous administrations may not have actively set out to make dealing with public services a burden, or to cripple our nation’s military readiness with policy clutter amounting to hundreds of copies of War and Peace, or create a veto-cracy that limits our ability to build infrastructure. But neither have they made fixing it a priority. This one can, and should.

Our two parties (and even the factions within them) often speak about state capacity in very different languages and have differing priorities for where that muscle should be deployed. But the vast majority of elected leaders on both sides of the aisle would like the bureaucracy to be capable of achieving the missions it is assigned

 

Where is the Forest Service Clearcutting Today and Why?

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We’re going to dive down to the “why,” at least on one forest, to satisfy the silviculturally curious, but this handy table shows us where clearcutting is happening in terms of Region. I’d like to step back a minute and say that my perspective depends on my observations at a specific spatial and temporal scale, and also how I perceive them, for example driving through California post-wildfire is different from info derived from satellite photos.  Point being, everyone, including researchers, can be “right” in their own observations, but not give a complete story.  It’s only in engagement with each other, and with various kinds of data, that we can get closer to an overall picture of how things are and why people think as they do.

 

Anyway, the tables go back to 1984.

I asked Google AI to plot clearcut acres for me from 1984 to 2025.  Google AI even made up a narrative to go with it! I don’t know how true the narrative is. Or really even the plotting, but..

So it looks like if you were in R-3 or 6, you would think “there is no clearcutting” but if you were in Rs 1,2 and 9, you might think differently. Or if your career began in the 1970’s or 80’s, it might seem like there is little to no clearcutting comparatively.

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To get to Forest, I think I would have to dive into FACTS, which would be a handy thing to be able to do (and might be handy to compare fuel treatment acres over time), but here is what Google  AI said I would need to do. Maybe there’s still time to consider a Peoples’ Non-GIS Database for info people have proven to be interested in?

No, the publicly available summaries from the annual reports do not break down these totals by individual National Forest.
The standard published source for this data—Table 20 of the Annual Reforestation and Timber Stand Improvement Report—aggregates clearcutting acreage strictly at the Regional level. [1]
To obtain the 2024 clearcutting totals for individual forests within Region 1 (such as the Flathead, Bitterroot, or Kootenai National Forests), you must access the raw FACTS database layers directly using one of the following approaches:
    • Download the Geospatial Data: You can download the raw shapefiles from the USDA Forest Service Enterprise Data Portal. By uploading the Activity_TimberHarvest layer into GIS software (like QGIS or ArcGIS), you can filter the data by Fiscal Year (2024), Region (01), and FACTS Activity Codes (4110 through 4119)—which explicitly denote clearcutting—and group the results by the NATIONAL_FOREST_NAME attribute field. [1, 2]
    • Use the ArcGIS Online Portal: You can use the interactive ArcGIS FACTS Harvest and Silviculture Portal to visually filter for Region 1 projects, click on specific management boundaries, and view the attribute tables containing the exact acreage for that specific forest unit.

    • Submit a FOIA or Info Request: If you do not have GIS software, you can contact the Region 1 Regional Office in Missoula, Montana, or the specific forest’s silviculturist to request a copy of their localized FACTS tracking spreadsheet for FY 2024.

Would you like the exact list of FACTS activity codes used for clearcutting to help you filter the GIS database, or are you looking for details on a specific logging project in Region 1?

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Wildland Firefighters and Everyone Who Supports You.. You All Did Great This Year!!!

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The Caribou-Targhee Camp Crew Unloads Equipment coming back to ICP..

Well, fall is in the air. In our neck of the woods, the aspen leaves are turning and the morning air is cool.

We’ve gotten through another wildfire season. But basically most of the coverage we have seen  in the media during this year has stressed potential future problems, or blamed problems on the current Administration. From a piece by James Peron in Medium:

It’s not the journalists fault; they are selling the public what the public wants. And when they have a terrifying story, or can take a gruesome one and make it sound worse, they sell more papers and that means higher profits. Whatever their politics they are profit-seekers at heart.

I know plenty of journalists would be horrified at this — certainly many who attended the same journalism classes I did —and simply wouldn’t acknowledge it. I actually suspect they don’t see it this way. They are merely reporting the “most important” stories and that means the most horrific news they can find.

They wouldn’t even notice they look for the bad news. It’s just good journalism but it leads to faulty perceptions resulting in bad policies because unscrupulous politicians use fear to buy votes.

Of course there have been problems, including the high rate of burnovers. I don’t know the reasons and it’s possible that a variety of causes contributed to each one. I am against generating overall conclusions until the reports are out. To whom is it important to hurry to diagnose before the facts are in? And why?

But while news folks tend to focus on the latest bad, or predicted future bads, maybe there should be just one story on how well things generally worked in what we were warned would be a devastating fire year. Remember this Outside piece from May of this year?

Why 2026 Could Be One of the Worst Wildfire Seasons in Recent U.S. History

Extreme drought, overstretched crews, and a sweeping Forest Service restructuring are converging into what experts fear could be the most volatile fire year in U.S. history.

Doesn’t it seem odd that this article focuses on the Forest Service instead of the real wildfire reorganization at Interior?  I wonder why that is?

Some experts like Duncan disagree, saying that although these cuts and changes aren’t directly targeting firefighters on the ground, they erode the foundation that keeps those crews operating safely.

“Morale is terrible right now,” Duncan said. “We lost a lot of folks through DOGE cuts, and more through delayed resignations and early retirements. There’s a huge network of support behind the scenes to help the firefighters doing the actual work, and a lot of those folks have left. With the proposed reorganization, getting rid of offices and research stations, we’re losing even more of that support network.”

Of course, moving peoples’ offices doesn’t make them unavailable for fire assignments.  But it meets the “sounds vaguely plausible” and “fits the narrative” criteria.

But the good news story is that everyone pulled together- the folks in the brand-new USWFS, the Forest Service, States, counties, and crews of all kinds- even folks from other countries, and we got through a really bad fire year.

This is due to the effort of people, some working without proper housing, without communications capabilities that most of us take for granted in this day and age, and all the other difficulties that are could easily be enumerated.  Of course, some of us need to focus on what is not working and fix it.

My concern is that we don’t give appropriate attention, value, and gratitude to the people who are making this work- firefighters, support folks, those doing the Wrok while people are gone on fires, and the families of firefighters.  All are part of the whole who have made this season, scary going into it, work.

So thanks to all of you!!!!!

 

Follow-up to Other Stories and Questions

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Some miscellaneous tidbits, following up on other stories…

1. What is the linkage between bureaus and the USWFS and how is it supposed to work?

The Office of Communication at DOI got right back to me when I asked the question about how things are supposed to work between the land management agencies and the USWFS, so shout-out to them.

The transition guidance issued in April is current.

The increasingly complex wildland fire environment now requires a professional workforce that is positioned to meet wildfire response and mitigation needs year-round. The U.S. Wildland Fire Service works in close collaboration with the Interior Department’s land management agencies to ensure fuels treatments, wildfire prevention strategies, and post-fire recovery efforts are fully aligned with public land management goals. This integrated strategy is intended to meet wildfire response needs while also building long-term landscape resilience.

2. Do Piles of Logs Left Over From Wildfire Suppression Actions Go Toward FS Timber Targets? Thanks to Andy Geissler of AFRC for this one!

Most of the time the Forest Service will sell log decks associated with fire suppression in a competitive manner in the same way they sell green timber sales. You can take a look at the Willamette National Forest’s current timber sale page and find four deck sales over the past year: Willamette National Forest | Timber Sales | Forest Service.

The volume sold is part of the agency’s accomplishments. The Forest Service has a unique “salvage sale fund” that often pays for these sales. If those funds are unavailable, they will typically use “timber” dollars (i.e. National Forest Timber Management dollars (NFTM)). However, both the salvage funds and NFTM fall under the blanket “timber program funding” according the agency’s accounting. Bottom line, these deck sales are funded by timber dollars.

It’s also worth noting that, in most cases that I’m aware of, the fisheries program gets “access” to the logs in these decks for in-stream wood placement. In some cases I’ve seen the Forest Service haul logs to a location and then fly them into rivers and creeks via helicopter. That work can be funded with timber receipts too.

Conversations in Comments to Bring Forward to More People

3. Litigation is Used to Affect Policy. It’s really OK. People who have different views use legal means to achieve their ends. These organizations tend to also work in politics via their c4 wings,  and policy. That’s fine. Jon said, and not to pick on him, but I’ve heard this before,

Litigation is not an adversarial process for “determining policy.” It determines what the law requires.

In reality, there are entities that use legal means to pursue their ends. Folks like Earthjustice are pretty direct that that’s what they’re doing. I also get it that folks who use this method would want to create executive branch actions that have legal hooks that they can use. And they will resist changes that seem like common sense to many of us, that they argue could interfere with their access to the levers of decision-making.

For example, this letter about FOFA (my understanding is that the current Senate version is 150 days).

Section 121 also dramatically limits the time to seek judicial review to 120 days after the date of publication of a notice in the Federal Register of agency intent to carry out the fireshed management project. This abbreviated timeframe places an undue burden on interested parties and communities with limited resources and would likely have the unintended consequence of leading to more litigation, not less, as interested parties may be forced to file suit to protect their legal rights. This is especially true if a claim requires a pre-suit notice period, such as the 60-day notice period required by the ESA. Finally, Section 121 creates a new, restrictive standard for standing to sue by requiring a litigant to have participated in the rulemaking in a very specific way that goes beyond the standard required by federal courts for Article III standing. We therefore oppose this provision of the bill.

Note what groups signed this letter to the Senate.

Like I said, it’s really OK for them to have their views and pursue them in whatever ways the US governments systems allow. And it’s equally OK for others to push back in courts. Personally, in my lived experience, courtrooms are not the best place to settle federal lands disputes, and we should be more transparent and design policies that favor other means of dispute-settling, but that’s the way it is.

4. More on How the USWFS and Bureau Interface Will Work

As an FS retiree, I’m having trouble understanding Jesse’s comments, I think at least in part, because I don’t understand how the DOI operates without what we would call “charge as worked.” From my FS experience, it seems like budgets are limiting… if you have the budget and don’t have the people, you can contract or grant the work. If you don’t have the budget, you will just do less. Anyway, maybe someone with both FS and BLM experience can translate.

If it were the FS, for example, (and say the wildfire folk were stovepiped in a similar way) all the “Wildfire Folks Approved” projects would have employees doing monitoring, NEPA, etc. would charge to the Wildfire account. If the FS wanted to do prescribed fire for other reasons than fuels, they would have to fund it through the benefitting function. Of course there is a tendency, when many functions benefit, to assign the charges to the function with the most available bucks. So there will be fuels people deciding if fuels bucks should be used.  Wouldn’t we expect wildlife people to decide if wildlife bucks should be used on projects intended to help wildlife?

So when I look at the transition function list, I see the issue as “who is paying for it” and not so much “what is done.” Maybe the way people are paid in Interior makes the whole thing more difficult than it needs to be? And would that be a good argument for keeping the FS out of Interior (if they don’t use “charged as worked.”)?

I Still Cry for the Mountains: Guest Post by Dave Daley

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I don’t usually post on Sundays, but was off Friday enjoying the National Forest fall aspen. Also I finished a helpful and hopeful recent book by Spencer Cox called Off Ramp: How to Be a Peacemaker in an Age of Contempt. It’s helpful for the work we do here, and reminds us of the importance of listening. Cox is a big fan of listening and the back and forth of the legislative process for resolving disputes and moving policy forward.

What strikes me about the ongoing discussion of wildfire strategies is that it doesn’t seem like anyone has convened a group to hash it out. We have people who say, “let’s not do it”, some that say “hey there have been problems, let’s fix them”, and those that say “everything was fine until the current Secs pulled out a full suppression strategy.” I wonder if they are ever in the same room, engaging. Convening this group- or identifying problems and fixes- might be a good task for a foundation somewhere.. Has someone already done it?

So let’s listen to one person’s experience.

I Still Cry for the Mountains Dave Daley

My family are cattle ranchers in the northern Sacramento valley. We have called Butte and Plumas County home since my ancestors came in the 1850’s searching for gold. We have a deep, almost reverent, connection to the land. We live and work in two different ecosystems — the oak woodlands of the foothills where our cattle graze from October to May, and the mountains of the northern Sierra Nevada where the cattle spend the summer on private and federal land.

Five years ago this week we received news that the Bear/North Complex fire had jumped the Middle Fork of the Feather River into our grazing permit and in twelve hours burnt almost 194,000 acres. It eventually burnt close to 350,000 acres, killed 16 people, and became the 8th largest fire in California history. The initial maelstrom was fueled by winds over 50 miles per hour in steep, rugged and heavily timbered country. Words cannot describe the scope and intensity of that blaze.

This was a “let burn” fire that had started in mid-August and had been burning for almost three weeks in rough terrain. The United States Forest Service (USFS) made a conscious decision not to extinguish the fire because of difficult access and risk to firefighter safety. And the pervasive assumption that “good fire” will reduce fuel loads. This wasn’t a “good fire!”

I understand the decision to prioritize firefighter safety, but aerial suppression might have protected personnel, and ultimately saved two towns, an entire ecosystem, the wildlife and my cattle. Instead, the USFS decided to expand the “let burn” area and drones were used to light more fire. The previously predicted deadly winds came soon after. I often wonder what would have happened if they had not purposely expanded the fire’s footprint. The outcome might have been the same, or perhaps some areas would have been spared leaving behind a patchwork of burned and unburned tracts, where wildlife, seedbanks, springs and the beauty of the mountains still existed. Instead, we only had complete death. As we searched for survivors while the fire was still burning, I watched as the few remaining green spaces were intentionally burnt. What wildlife lived, did so no longer.

When the smoke finally cleared in early December, sixteen lives, the towns of Berry Creek and Feather Falls, and hundreds of homes were lost. And an incredibly beautiful ecosystem destroyed. Almost 400 cows and their calves were burnt to death, along with all the wildlife. We lost beautiful landscapes that we had loved for generations. The federal government never accepted responsibility nor paid for damages to private property or restored public lands. You can’t pay enough to replace life or replace an ecosystem that was literally cooked. The fire burned so hot that in places the soil was sterilized.

After five years, I have realized that we always view fire from the ecosystem we know best. If we have witnessed fire in a mountain, sagebrush, desert, juniper or grassland ecosystem, then we assume that is how the fire will respond, and the land will recover exactly as it is imprinted in our memory. And, if you are from an urban setting, you may have no vision of the nature of forest fires. So many of my ranching friends from other biomes have said to me, “I bet the country has recovered and your cattle must be doing great.” They don’t understand the impact of catastrophic fire in the big timber country of the Sierra Nevada. It hasn’t recovered and it may not in my lifetime. What we are doing to manage fire isn’t working in all ecosystems.

Creating effective approaches to fire requires us to tailor our response to the ecosystem; mountain, foothill, desert, valley; wet or dry; hot or cold. And then there are so many variables when the fire is active– topography, wind, humidity, vegetation type, fuel load, moisture, temperature, season. The diversity of landscapes requires flexibility and an awareness of and responsiveness to local conditions. The current model seems to be a one size fits all where the USFS approach is to create a perimeter, often miles from the fire, and intentionally burn to the line. How many acres are needlessly burnt? Or the fire grows and escapes, as was the case with the Bear/North Complex.

To be clear, this is not criticism of firefighting personnel, as they work in dangerous conditions that most of us cannot imagine. I applaud their work. This is simply a critique of the federal approach to managing forest fires.

Roughly half of California is federal land that is not controlled by Sacramento, but managed by Washington D.C. Both parties have failed the environment and the people. We never seem to focus resources on pre-fire fuels reduction, nor post fire restoration. We spend billions on suppression in a failed model that the government has created.

Policies developed from afar and without any understanding of what happens on the ground rarely work. Who makes federal decisions regarding fire suppression? Is it someone with local expertise who understands both the human and ecological implications of their decisions? No.

After the fire was finally put out three months later, I have yet to see a plan for post fire recovery and restoration. I have watched the burn scar turn into a brush field. There are no conifer seedlings, almost no wildlife and five years have passed. Catastrophic burns in big timber will convert to a brushscape in two or three years. The absence of policy, resources, and political will, just lead to more fuel for the next fire. We are left with standing dead trees surrounded by dense brush four feet deep.

The federal government has abdicated responsibility for post fire management. In our grazing permit, there has been a token attempt at dead tree removal on a few acres along one road. There appears to be little action taken to address the effects of forest fires, which may be due to resource limitations or policy constraints. If they don’t move quickly (which the USFS is incapable of), it is too late to salvage the timber, repair the roads, and open the campgrounds. A myriad of hurdles cause delay until nothing is done.

There is another model. Our grazing allotment is mixed public and private land. The private timber company immediately began harvesting as quickly as they could, and shortly thereafter began replanting. There aren’t any new conifers growing on the federal land five years later—the seedbank for trees was destroyed. Completely. Contrast that with the private timber company land, where dead tree removal began immediately and nine million conifer seedlings were planted in three years! Sure, there may be an economic incentive to do so, but that effort is still essential for the health of the land.

There are alternatives to the current federal approach. The cost of megafires to taxpayers is astronomical. The Dixie fire in five northern California counties in 2021, a massive fire of 963,000 acres, also fueled by backfires, cost $637 million to suppress. What if those federal funds were directed to fuels reduction? Forest management could include fire prevention strategies such as thinning, timber harvest, grazing and the use of prescribed fire, designed for the specific ecosystem. I envision a time when fuel loads have been reduced to the point that a lightning strike would not be a major concern because our National Forests are healthy and natural fire has returned to the landscape. I know. I’m a dreamer.

Some would suggest that climate change has resulted in the increasing severity of catastrophic wildfires. If that is the case, then fuel load reduction becomes even more essential. We can’t simply keep adding “fuel to the fire”, as we have for so many decades.

Post-fire management is just as critical to the health of our federal lands. Removing dead timber, replanting, stabilizing the soil, protecting waterways, repairing roads are all essential and should be prioritized in federal lands management. If we don’t do some of these basic steps, we will simply spend more money on the next fire and destroy the forest again.
Fire destruction and recovery is not just a California issue, nor a red state/blue state problem. This is federally owned land and has been managed the same under both Democratic and Republican administrations. I truly believe that the remote forest is “out of sight, out of mind”, and there are not enough of us in rural areas who witness the destruction to even have a voice.

When there aren’t enough votes to get you elected, what politician really cares? And, if the public doesn’t understand how this devastation affects all citizens, there is even less political will for change. The effect on air quality, water quality, soil stability, wildlife habitat and so many other long term ecological impacts are quickly forgotten if you don’t see the destruction. I see it every day and can’t easily forget.

Are there simple answers. No. But we need all available options to reduce catastrophic fire. It seems we are developing small contingents that only advocate for their solution…. “Grazing sheep and goats is good, cattle are bad”, “thinning is good, logging is bad”, “prescribed fire is the only practical solution, everything else is not natural”, “leave it all alone, humans should never intervene.” Isn’t it possible that we need all tools available for forest health, and what works in one biome may not work in another? And the best way to deploy those tools is to listen to the people who live there. Listen to the land itself. Please.

The recovery is painfully slow in the Bear/North Complex fire. I realize the intensity of that fire is more severe than many others. It may require different solutions. My hope is that we can work as hard at reducing fuel loads pre-fire and at post fire restoration, as we do at suppression. Suppression requires crisis management when all hell breaks loose. Planned, thoughtful fuels reduction using all available strategies would benefit the land and the communities. And we cannot forget the critical importance of restoration. It would be far more cost effective for taxpayers, better for the economy and so much better for the landscape and forest health. I can only hope.

How Is the Wildfire/Land Management Nexus Going to Work at Interior?

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BLM staff member assesses vegetation debris in a forested area of King Mountain from horseback.
A BLM Colorado staff member assesses the amount of fallen tree limbs and vegetation debris in a forested area of King Mountain from horseback. Dead and overgrown vegetation can increase the risk of wildfire spread and damage. BLM fire managers and range specialists routinely scout areas to consider for future fuels management or reduction projects. Implementing these projects offers many benefits to include improving firefighter and public safety and reducing wildfire risk to infrastructure and public and private lands. (BLM photo by Kristy Wallner)

Some folks have a talking point with regard to the fire folks in USDA moving to Interior (I don’t want them to move either but..) “you can’t separate wildfire from land management”. This even is used as a reason for line officers to give up power to fire managers within the FS. Still, Interior is apparently trying this. As usual, the devil is in the details. I’ve sent questions to several BLM communication folks, and I don’t get any answers. Maybe they haven’t figured it out yet. still, I did run across this.. So what happens in a few years when Interior figures it out.. will these folks need to change those talking points? Why not pick more resilient talking points now?

I also wonder whether this project would be litigated if it happened in Montana.. do the legal hooks of certain T&E species provide a critical habitat for litigators?

SILT, Colo. – The Bureau of Land Management’s Colorado River Valley Field Office is moving forward with a plan to reduce wildfire risk, improve forest health, and offer suitable timber for sale. The work will cover nearly 5,500 acres near King Mountain and may begin in summer or fall 2026.

“As we get ready to put this project into action, we’re looking forward to creating conditions to help slow future wildfires,” said U.S. Wildland Fire Service Fuels Specialist Chad Sewell. “The work we’re doing out here will make a noticeable difference on the ground and help keep this ecosystem strong for years to come.”

Expected Benefits:

Improved safety for firefighters and the public
Reduced wildfire risk to recreation areas, infrastructure, and nearby communities
Healthier habitat for wildlife and better recreation experiences
Safer and easier-to-use foot and horse trails after clearing away fallen branches and dead trees
Better livestock distribution, easing pressure on nearby Greater Sage‑Grouse habitat
The BLM will partner with the Colorado State Forest Service under the Good Neighbor Authority to sell appropriate timber as commercial products. This collaboration will help BLM reduce wildfire risk while supporting local industries and strengthening local economies. The authority, approved by Congress, allows BLM to enter an agreement with the state to perform forest, rangeland and watershed restoration work. The state will retain any funds from timber sales under the agreement for use on additional GNA projects.

“We’re excited to team up with our partners on a project that benefits the community and the landscape,” said CRVFO Field Manager Lisa Dawson. “Selling the timber we remove reduces waste and helps support local mills and the people who work there.”

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So the fuels specialist (seems to be) still there (in the same office), and works for USWFS, and seems to still be involved in project design and communication. Is that how it’s going to work in the future? Is the USWFS just a question of readjusting so that wildfire folks have more control over wildfire-related (and funded) local projects, and continue to be available for national suppression efforts?

Look, no one expects USWFS to have it all figured out, as if it will be forever. Fire folks are famous for doing lessons learned and improving the way they work. But still, what they are currently thinking, and the expected trajectory of where they’re going would be nice to know. But perhaps I should be asking the USWFS and not BLM.

Read It Yourself: NOI Preliminary Description of Proposed Action, Travel Management

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There is bound to be quite a bit of coverage of this NOI. So I thought I’d get the proposal itself before we get to others’ statements about it. The problem I’ve noticed over time with proposed rules is that reporting tends to focus on “the worst thing that could happen” not “what is likely to happen after the regulation filters its way down to the field level.” This makes for engaging headlines and quotes, but may leave readers in the dark about the likelihood of feared bad things transpiring. We may have talked about it some, but I don’t remember talking about the e-bike provision.

Here we go:
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Preliminary Description of Proposed Action
The proposed action would establish a new national policy to guide local travel-management decisions, remove the minimization criteria in subparts B and C, revise other identified process requirements, and separately amend subpart A as described below.

Future changes to public access covered by the amended regulations would be governed by the proposed access rule, applicable laws, valid existing rights, other governing instruments, and public participation and governmental coordination requirements identified in the amended rule, Tribal consultation requirements, local access needs, and documented resource and safety considerations. Maps showing designated roads, trails, airfields, trailheads, and other access routes and points would continue to be published and periodically updated for each NFS administrative unit.

The proposed regulations would establish a new regulatory framework governing local decision-making. The Department invites public comment on the following components of that framework:

1. The amended regulations would establish a presumption that existing roads, trails, airfields, trailheads, and other access routes and points on NFS lands are open to appropriate public use unless closure or restriction is required by applicable law, valid existing rights, or another governing instrument, or is supported by specific, documented and justifiable reasons based on science-based resource conditions, public safety, conflicts among uses, or maintenance and administrative capacity. This presumption would include access along section lines in certain national grasslands in North Dakota. The presumption would not itself establish the existence, ownership, or scope of a public right-of-way or establish Forest Service jurisdiction or legal access. Seasonal restrictions could be applied. The amended regulations would require, subject to available appropriations, an annual unit-level process to identify closed or highly restricted trails, roads, airfields, trailheads, and other access routes and points that may warrant reconsideration. The responsible official would conduct the review and indicate which routes or access points may be reconsidered for a change in status. A route would be reopened only through the process prescribed by the proposed access rule and only if reopening would be consistent with applicable law, valid existing rights, other governing instruments, available appropriations, and the governing access and closure criteria.

2. The proposed access rule would establish a requirement to consider new roads, trails, airfields, trailheads, and other access routes and points where appropriate to increase access. The policy would not itself authorize construction or commit resources and would remain subject to applicable law, valid existing rights, governing instruments, site-specific review, and available appropriations.

3. The proposed regulations would address Forest Service management of NFS airfields and the use of NFS lands for aircraft landing and takeoff. It would identify the regulations and existing airfield or aircraft restrictions proposed for amendment and the criteria and process for opening, restricting, or closing an airfield.

4. The proposed access rule would establish processes and conditions for authorizing limited off-route motor vehicle and other motorized equipment use for, among other things, downed big-game retrieval, firewood collection, dispersed camping, and for designating areas for over-snow and other motorized recreation. The proposed regulations would specify whether each use would be authorized through a route or area designation, a written authorization, or a categorical exemption and would establish applicable geographic, seasonal, vehicle-class, and resource-protection conditions.

The proposed action would separately revise specified portions of subpart A. Specifically, section 212.5(b)(1) would be revised to replace the current minimum-road-system requirement with criteria for determining an adequate and appropriate forest transportation system, including access needs, resource protection, safety, maintenance capacity, and applicable land management plan components. Section 212.1 would be revised to define the vehicle and use categories subject to different designation or exemption requirements specified in subparts B and C and part 261, rather than relying exclusively on a motorized or nonmotorized classification. For each provision, the proposed rule would identify whether it would be eliminated, retained in the CFR, moved to another CFR provision, or moved to Agency directives, and would explain any resulting change in legal effect, enforceability, or third-party rights and obligations.

The proposed action would add specified categories of exempt vehicles or uses to the designation and prohibition framework in 36 CFR parts 212 and 261 and would revise that framework to accommodate new vehicle types and uses without relying on a binary motorized or nonmotorized classification.

For purposes of the proposal, “class 1 electric bicycle” would have the meaning in 23 U.S.C. 217(j)(2)(A) and (B)(i). The proposed action would exempt class 1 electric bicycles from the motor vehicle use designation requirement in 36 CFR 212.51(a) and the prohibition in 36 CFR 261.13 when operated on an NFS trail where bicycle use is allowed, subject to applicable land management plan direction, seasonal restrictions, orders, and site-specific restrictions adopted by the responsible official under the criteria and procedures in the proposed rule. The EIS would analyze an alternative retaining class 1 e-bikes as motor vehicles subject to motor vehicle use designations and alternatives adopting broader or narrower exemption conditions.

Any additional categorical authorization for low-powered electric mobility devices used by persons with mobility disabilities would be defined by objective criteria in the proposed rule, including the covered devices and the scope and conditions of the authorization, and coordinated with applicable disability-access requirements. Any additional authorization would supplement, and would not limit, existing rights or Agency obligations under applicable disability-access laws. These changes would be evaluated in light of approaches used by other Federal and State land management agencies.

With regard to subparts B and C, the proposed action would establish an access-planning process and would not itself authorize construction or other ground-disturbing activities or projects. The access presumption set forth in the national policy would guide future decisions and would not itself open a currently closed route, airfield, trailhead, or other access point except to the extent that the amended regulations expressly make a specified vehicle- or use-specific exemption self-executing. Existing motor vehicle use designations, including the designations shown on MVUMs and OSVUMs, would remain in effect until revised under the amended regulations. Prohibitions established under other authorities would remain in effect until modified, rescinded, or expired under those authorities.

Future site-specific designation decisions would be made by local officials after analysis and evaluation of land and resource conditions, consistent with applicable law. If the rule removes sections 212.52 and 212.53, it would identify the public involvement, governmental-coordination, and Tribal-consultation requirements that will govern future designation and revision decisions.

Thank You to Employees! And A Blast From the Past- Working Guidelines

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Welcome back from Labor Day, everyone!
I wanted to give a shout-out to all the great Forest Service employees who continue to be helpful and doing their work. I think sometimes this gets lost, as from the media it may sound like all they do is complain and worry. I’m sure that much of that goes on, (it always has but there wasn’t social media to amplify it) but let’s not focus on that, instead of all the good work they are doing.

And a special thank you to wildland firefighters, support folks, LEOs and recreation folks who had to work over the weekend. And a very special thank you to the folks who do extra work back at the unit while others are on fires. And of course, thank you to families who support all these folks.

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A few posts ago I was thinking about “affirm everywhere, counsel in private” and who and what that applies to. Certainly we can criticize policies without criticizing individuals in public. In general, I think we do that fairly well here at TSW. It seems like it’s a new thing (in some retiree circles) to criticize Chief Schultz personally, I don’t really know why, when that seemed to be off-limits in the past. Anyway, with a special tip of the hat to Jim Z, who may have been on the Ochoco at the time, I thought I’d share these working guidelines. For me, they still make sense, although their application to an idea-exchange forum like this one is more complex.

List of Forest Service Research Facilities to be Kept and Those to Be Closed

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Within hours of the previous post in which I quoted Chris French using Stoneville as an example and Alex Friend agreeing..and my pointing out that it had been on the block intermittently for probably 30 years..

“as much as I think everybody loves the Stoneville research site in Mississippi, there’s 14 buildings there and we staff it with four people. I have to manage our facilities somehow. And unfortunately, R&D has more examples like that than others. I’ve got a district ranger office that is leased in that Stoneville site right up the road. We’re looking at it right now. Is it better to move that district ranger office to Stoneville and use the facilities there or invest in a better office for essentially the district ranger’s office and move the four people in Stoneville there? That’s what we mean by evaluating. “

someone sent me the list, and Stoneville is retained. Here’s what the Chief said:

Forest Service Chief Tom Schultz emphasized the closures and consolidations will not result in any forced staff reductions and that work will continue without interruption.

“This announcement reflects our commitment to retain the staff our mission requires while responsibly reducing our facilities costs. Local facility consolidation will help us put more of our funding toward mission delivery and cutting-edge research, rather than brick and mortar we no longer need. This puts us on a sustainable path, retains our employees, and ensures we have the right geographic distribution of labs and duty stations across the agency. And importantly, this produces more than $8.8 million in annual lease savings and more than $8 million in deferred maintenance savings – ensuring American taxpayers receive the maximum value for every dollar entrusted to us,” added Chief Schultz.

Here’s a link to the lists.

My question is, for example, Placerville has an SO, a nursery, and the Institute of Forest Genetics.  The plan (I think) is for a State Office to be there as well. Do we know what groups will be in what buildings yet? Does this table mean that researchers will continue to be located at research facilities and no matter how few employees are there the facilities won’t close, or maybe other people will move in? Maybe there’s another layer to all of this that locals would be interested in.

I’m assuming that we could probably infer from these closures and where other FS facilities are located within the commuting area, where these folks are likely to go. But again, it might be nice for the FS to publish where people are going.

23 Research Buildings Closed Instead of 64- Possible End to “End of Science” Narrative

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I loved the headline..

US Forest Service closing 23 research facilities as part of reorganization under Trump

Dear AP, I think everything the Executive Branch does is “under the current President” so I don’t think you need to say it every time.

What I think is interesting about this is that if you track what Chris French has told us,  that they were looking at the issue, and would probably come down with fewer than the original , it seems like Chris has been telling us the straight scoop.

The U.S. Forest Service is closing 23 research and development stations in more than a dozen states as part of an organizational overhaul under President Donald Trump that is intended to trim costs and concentrate the agency’s resources in Western states, officials said Thursday.

This is always confusing as “stations” were the Research Stations which were an administrative layer.  But these could be more accurately be called “buildings”.

The work being done at the research stations will continue at other sites, Forest Service Associate Chief Chris French said in an interview. An additional 41 research facilities that faced possible closure will remain open after local officials and members of Congress raised concerns about the reorganization, which was announced in March.

“Our primary goal was to get our facilities costs under control,” French told The Associated Press. “We’re not closing any ongoing science activities. We’re not closing any of the experimental forests that are important to our researchers.”

Chris has been consistent on what he says about this, from the transcript of the Q&A session Chris French had with NAFSR.

We do not intend to move researchers out of the locality of where they’re at. We do not intend to close experimental forests. What we do intend to do is consolidate our facilities into something more sustainable. And this is hard.
I think the messaging got really messed up on this. We’re doing our best to try to align that, and that’s on us. But we’re going through and evaluating those facilities. Some of those we’ve looked at and said, no, this makes no sense. You don’t close this. Th example I would give is like up on the Okanagan Wenatchee.
There are other sites we need to be looking at hard. As much as I think everybody loves the Stoneville research site in Mississippi, there’s 14 buildings there and we staff it with four people.
I have to manage our facilities somehow. And unfortunately, R&D has more examples like that than others.
I’ve got a district ranger office that is leased in that Stoneville site right up the road. We’re looking at it right now. Is it better to move that district ranger office to Stoneville and use the facilities there or invest in a better office for essentially the district ranger’s office and move the four people in Stoneville there? That’s what we mean by evaluating.  We have multiple sites where we have multiple facilities, NFS, state and private, and R&D, all within the same locality area, and most of them are underutilized.
And we’re trying to have frank conversations with our partners. We have experimental forests where we have facilities that we don’t staff anybody at, and they are primarily used by universities and others. And we’re saying, you want to take these on?
Because right now they represent tens of millions of dollars of deferred maintenance and other maintenance and utility costs that I can’t afford to pay. That’s the conversation we’re trying to have.
We’re not trying to move scientists. We don’t want to lose the data that they have, but we also have to make sound facilities decisions

Alex Friend, member of the Board at NAFSR and former Deputy Chief for R&D:

I, you know, certainly agree with Stoneville and similar cases, so that’s long overdue, and that’s a great anecdote. I hope the other cases are similar.

Even when I worked in R&D we had facilities maintenance and empty space issues, and some of the same sites cropped up-  and Alex agrees that there are issues.

Chris: Alex, in our working with the department, the initial messaging that went out on this was confusing and bad and it’s created this. Now, the silver lining is I think the outrage mixed with the president’s budget; we suddenly have leaders like the Secretary talking about the importance of science.

It could be that OMB was pushing on one of its bizarre green eyeshades crusades.. and the FS came out with this to create external pushback from legislators to the bad idea of getting rid of R&D. It should be noted that USDA also has NIFA and ARS, and they are apparently not the targets of equivalent OMB hatchet jobs.

As I pointed out at the time, the many times R&D has tried to close buildings, legislators and local officials predictably came out in force.  In this case, the FS made their announcement before they talked to these folks so.. the number was sure to shrink. This strategy is better as the research isn’t being closed out, and the scientists aren’t moving from the local area.  Win-win.  Meanwhile the legislators are now on their toes about FS R&D and (even more) likely to blow off any efforts to defund FS R&D, win win win! It’s actually pretty brilliant if that was the plan.

Bill Avey of the National Associated of Forest Service Retirees, an advocacy group, said the forest service has long struggled to pay for all its facilities and some opportunities for consolidation exist. But Avey, who worked at the service for four decades, said its current leaders including Chief Tom Schultz need to defend the importance of forest research more vocally.

“He should be doing a much better job of pushing back and justifying and explaining some of the research work,” Avey said. He added that the 41 facilities being retained likely would have closed as well if not for pushback from his group and others.

Honestly, as another retiree, and former NAFSR Board Member, I don’t think Bill knows what the Chief and Chris have actually done and said to those who matter in the Admin.  They might have run a complex operation as I described above.  So how does Bill know that the Chief “should have done” more? And what is this with retiree organizations criticizing current Chief’s  imputed actions or lack thereof, rather than policies? Whatever happened to “you catch more flies with honey than vinegar” and “affirm in public, counsel in private?”

The 95 employees at the research stations slated for closure will be shifted to other sites within their commuting areas, Forest Service Communications Director Chad Douglas said. The closures — along with previously announced plans to shut regional offices in Atlanta, Milwaukee and Portland — will save about $16 million, officials said.