Leading Through Change: Note from Chief Tom Schultz

Here’s a link:

Two thoughts I had:

“new governance models as we adapt to delivering contracts and agreements with fewer staff.”  I hope that these would included increased transparency (without FOIAing), clear accountability for deliverables (and how outputs and outcomes are monitored), and transparency about the accountability processes.

“We are offering lateral opportunities in key mission areas like minerals and geology and active management.”

When it seemed like my skills in reforestation and genetics were becoming unpopular, I shifted into R&D in the WO, and finally, NEPA, through a set of opportunities and encouragement from various folks.  I think of JR especially who encouraged me to apply for the WO-NEPA job, way outside of my wheelhouse, and FN who thought my knowing about science might help.  I wouldn’t be here (judge for yourself if that’s a good thing or a bad thing) except for both needing to switch based on the currents of program popularity, and to the folks who believed I could apply my skills to a different line of work.  As a person whose skills were once in the “active management” camp, I’d like to put in a good word for minerals and geology for expanding one’s horizons and the opportunity to learn new things.

Here’s the Chief.

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Over the past year, we have experienced transformational transition. As you likely know, our upcoming reorganization work is not just a response to USDA restructuring, it’s something Forest Service leaders and employees have known was necessary for some time. This is an effort to optimize our workforce, sharpen our focus, and address fiscal solvency issues that have persisted over the past 12 months.

Given ongoing budget constraints, the agency made hard decisions to not bring back seasonal employees, strictly limit external hiring, and significantly reduce travel. Since that time, many of our co-workers and friends have retired, accepted voluntary separation offers, or left for other positions—leaving gaps at all levels of the organization. Underlying all of this is the anticipation surrounding what our new organization will look like—a process that began during the last administration and continues today.

You know these challenges better than I. You have been experiencing this on the ground and leading from where you sit through this uncertain time. Across government and in the Forest Service, we are experiencing things we haven’t encountered in a generation or more. While we await additional details, it is more important than ever that we meet this moment and convene and engage our teams.

I’ve shared that I believe it is important to listen more than you speak. With that in mind, I want you to know that I’ve asked your leaders to convene calls and spend time with you, whether in small groups or on regional calls. As we work through this transition, I want you all to engage in dialogue to hear and share thoughts, concerns, and ideas. Create space for others to share before you respond.

It’s important to remember that it’s OK not to have all the answers—none of us do. I have asked your leaders to provide stability and compassion.

As Chief, I’ve had the privilege of meeting with many of you across the country over these past few months. Our employees are dedicated professionals, passionate about their work and our conservation mission. Many entered civil service with a clear purpose: to care for the land and serve the public good.

I believe in you, and I believe in our employees.

As I said earlier, our upcoming reorganization work is an effort to optimize our workforce, sharpen our focus, and address fiscal solvency issues that have persisted over the past 12 months or more. What we do to move forward within that new structure is up to us.

As we navigate this time, I ask you to think about how we chart a course through the next chapter of our agency together.

Next steps

In the coming weeks, we may have more information about our organizational structure. In the interim, we are testing new governance models as we adapt to delivering contracts and agreements with fewer staff. We are implementing interim measures to maintain our readiness and deliver priority work around safety, communication, fire suppression, active management, minerals and energy development, and public access. We are offering lateral opportunities in key mission areas like minerals and geology and active management.

I ask you to stand ready to support this effort. Be ready to provide feedback, engage on transition teams, and lead discussions that acknowledge and carry forward the success of our organization.

We are living and leading in a truly historic moment. Years from now, I want us to look back and say we rose to the occasion together. That we navigated this transition while continuing to serve the American people in new, more effective ways.

This time represents both the ending of many things we have held close and the start of a new chapter in our agency. We will lead this work together and rebuild a cohesive, dynamic organization. Thank you for everything you bring to this work, and for your service, as we shape the next chapter of the Forest Service.

Forest Service and Related News Update/Off For a Week

I’m going to be off working on a presentation the rest of this week and next. I’ll share the presentation here when it’s done. I will be approving comments. Others are invited to post.

My latest info on the FS is that

1. there is no plan to fire probationary and excepted employees

2.RIFs are coming but need to be reviewed by a judge.

3. Chief wants to push decision making down to lowest levels

4. Chief is working on getting more purchase cards

5. Whatever the transition is, it is designed to have least impact to district offices.

So I’m leaving it there for now, and people with more information can add in the comments.

Other miscellaneous stories:

1. The Hotshot Wakeup Podcast on Timber Orders

The Hotshot Wakeup has a podcast interview with me about the Timber Executive Order.
Joe Trudeau commented:

Regarding the 25% increase in production: my deputy district ranger told me last week that they need to produce a five year plan to increase production over five years. They don’t need to move 25% more wood NOW, they need to make a five year plan. Big difference. Furthermore, if you look at the FACTS data for acres harvested, we already saw an increase in production under Biden (following a decrease under Trump term 1), so, USFS is already on a trend of moving more wood. Keep the trend going on current trajectory, and you have 25% right there. My final take on this: not much will change. USFS is a supertanker that changes direction very slowly and in small increments, and the shift between administrations is more talk and posturing than it is substance.

I agree with Joe, and would only add that “making a plan to do something” and “doing something” are not the same thing. I would also add that at some point, when enough “sky is falling” emails overflow my inbox, I tend to tune the organizations out.

2. NAFSR (National Association of Forest Service Retirees) Letters

NAFSR has a letter about the proposed wildfire agency. They also have letters about other federal lands issues on their website.

3. NASF Letter (National Association of State Foresters)

NASF  has a letter on reorganizing.

“State Foresters can play a critical role in the federal reform dialogue, provided they are included,” said Jay Farrell, Executive Director of the National Association of State Foresters. “They are informed, engaged, and ready to ensure positive outcomes for forestry and wildfire management throughout this transition. While we are eager for progress, we urge a thoughtful and collaborative approach to achieving efficiency.”

While looking for that one, I found this letter to new EPA Administrator Lee Zeldin. The letter highlights three policy issues:

*Reviewing and streamlining the Exceptional Events Rule (EER) for prescribed fire.
*Unlocking the Renewable Fuel Standard (RFS) for woody biomass, in line with clear statutory direction from Congress.
*Ensuring clarity in the definition and implementation of WOTUS under the Clean Water Act.

Please add any other letters on reorganization that you or your organization have written, in the comments.

4.  Affordable Housing in Resort Communities Where FS Employees Live

Using shipping containers, in Buena Vista, Colorado.

5. BLM Law Enforcement Officer Reinstated.

This is behind a paywall at E&E News. While I was looking for a non-paywalled version I ran across this from PEER in 2023.

“A 2021 announcement by Interior Secretary Bernhardt that all of BLM’s law enforcement rangers would henceforth be supervised by other law enforcement personnel has not been implemented.”

Someone sent me the E&E story:

Roth’s decision says Kriley qualifies for federal whistleblower protections, concluding that he was removed as OLES director because he alerted senior bureau officials that his immediate supervisor at the time was attempting to improperly influence internal investigations into possible ethical and legal violations for senior-executive-service-level employees. That supervisor was Mike Nedd, BLM’s deputy director and its top career official.

The decision says “Nedd directed him to provide advance notice into misconduct allegations against SES personnel,” which would have included Nedd himself. Kriley argued this was not allowed.

Roth agreed, noting that Kriley “credibly testified he felt this directive was an impermissible attempt to undermine the OLES’ authority and independence,” according to the decision, which was reviewed by POLITICO’s E&E News.

Nedd also tried to force the BLM law enforcement office to pay for a $330,000 settlement payment out of its budget, which Kriley objected to, the decision said.

That payment was for William Woody — Kriley’s immediate predecessor as OLES director, who was also abruptly removed as director in June 2019 under still mysterious circumstances. Woody challenged his dismissal in an age discrimination and disability complaint against Interior.

Woody eventually withdrew his appeal for reinstatement after reaching the settlement with the Interior Department.

Kriley, who before joining BLM served as a law enforcement professional with the State Department’s Diplomatic Security Service, testified that he felt Nedd was trying to punish OLES by suggesting the $330,000 settlement come out of the department’s budget. Ordinarily a settlement would come out of a specific legal fund, not a department’s budget.

I wonder what would happen if settlements came out of each unit’s budget in the FS? At least we’d know what was in the agreement and how much was paid..

5.  Softwood Lumber from the BC Perspective: Splitting the Collected Duties

From our friends in BC:

Canada and the United States have been without a softwood lumber deal since 2015 and B.C. softwood lumber exporters pay duties of 14.4 per cent, which are expected to jump to 34.5 per cent in the fall.

The industry also faces possible tariffs on top of existing duties after Trump ordered an investigation into the national security implications of lumber imports.

Eby has repeatedly questioned the purpose of the investigation because the province’s softwood lumber industry “poses no threat to Americans, except for more affordable housing,” he said.

The United States has collected $10 billion in duties so far, but that money remains legally locked up as Canada is challenging the tariffs as unjustified under the Canada-United States-Mexico Agreement.

Previous softwood agreements have divided up the money collected, and Eby said both the American government and Canadian producers could benefit from those funds, which he said is an “incentive” on both sides of the border to “get a deal.”

Niquidet with the Council of Forest Industries said American companies won’t be able to access a share of the collected money unless their government settles with the Canadian government.

He could not say how long it might take to negotiate a deal, but “if there is a fair deal on the table, it could go pretty quickly.”

B.C.’s forestry industry is the one of province’s most important exports, with Niquidet’s industry group pegging its contribution to provincial GDP at $17.4 billion in 2023.

6. Gators Study Gators

Finally, a safety tip from our University of Florida friends..

Most bites occurred following moderate-risk behaviors, such as swimming or wading in areas known to be inhabited by alligators. The highest proportion of fatal bites occurred after high-risk behaviors, such as deliberately entering alligator-inhabited waters. In contrast, low and no-risk behaviors, like walking near water or simply being present on land, rarely resulted in attacks.

“The takeaway lesson from this study is that many bites can be prevented if humans are aware of their surroundings and minimize risky behaviors such as walking small pets near bodies of water or swimming where alligators are known to be present,” said Frank Mazzotti, professor of wildlife ecology at UF/IFAS Fort Lauderdale Research and Education Center (FLREC) and an author on the study.

The most surprising finding was how high the percentage was for humans engaging in risky behavior. This indicates that humans, rather than alligators, are at fault in the vast majority of cases where bites occur, said Teshera.

The results emphasize that alligators aren’t seeking conflict, but they will respond when humans provide what scientists call an “attractive stimulus,” such as by splashing, swimming or entering alligator habitats.

UF/IFAS Tyler Jones

Although some bites happened without clear warning, in many cases, people unknowingly triggered the alligator’s natural response to defend itself or to hunt.

Researchers stress that humans are entering the environment of a large, wild predator much like hikers entering bear country or swimmers in shark-inhabited waters and should assume some level of responsibility and attentiveness.

May 2025 Recreation News Round-Up

 

With all that’s going on at the Forest Service, we’ve been remiss at rounding up recreation news, so here goes. Please add your own in the comments.

1. Lake Tahoe Basin Wide Trails Analysis Project

I couldn’t find much detailed news coverage of this decision, but I think it’s pretty interesting what the Lake Tahoe folks can do. Note what they did with adding trails. Here’s what the decision is doing (from the Draft Decision Notice September 2024).

Designate existing non-motorized trails as open to e-bikes (112.6 miles)
 Change existing motorcycle trail designation as open to e-bikes only (1.1 mile)
 Designate existing non-motorized trail as open to motorcycles (3.8 miles)
 Decommission Trails (2.5 miles)
 Construct new trails open to e-bikes (27.5 miles)
 Construct new non-motorized trail (14.7 miles)
 Construct new motorcycle trails (4.2 miles)
 Designate existing closed road as open to e-bikes (2 miles)
 Designate existing unmanaged trail as non-motorized (1.7 miles)
 Construct three new trailheads (Pine Drop, Brockway Summit, Elks Point). Trailheads would include a paved
parking lot and visitor information signage. Restroom facilities may be included.
 Upgrade stream crossings
 Upgrade trails for Best Management Practices
 Install wayfinding and interpretive signage
 Update the LTBMU Motor Vehicle Use Map (MVUM)

Here’s the need for change:

There is a need to provide a sustainable trail system meeting National Forest Trail Management Standard, including low-maintenance design principles, diversity of experience and challenge opportunity, and appropriate trail use guidance.
 There is a need to update the wheeled vehicle designation of the National Forest System trails and roads to reflect the use of e-bikes and update the Motor Vehicle Use Map to reflect these changes.
 There is a need to provide trail system connectivity to logical access points, such as trailheads, public transit routes, community centers and neighborhoods, and underutilized areas.
 There is a need to manage and upgrade some existing unmanaged trails.
 There is a need to provide a trail system that incorporates “stacked loop” design – trail experiences of different length, type and challenge exist from common access points.
 There is a need to provide Aquatic Organism Passage at trail crossings.
 There is a need to provide additional capacity on popular recreation trails.
 There is a need to limit potential impacts related to use conflict, or overuse of popular trail sections and areas.

Seems like many of these would apply in many places; perhaps other forests don’t have the capacity to take this on.

2.  The Continuing Steamboat Mountain Bike Trail Controversy

There’s plenty of coverage of this one. Here’s a story from 2019.  From last month:Forest Service changes to Rabbit Ears Pass mountain bike project have advocates hopping mad

That seems like six years, almost as long as fuel treatment project time frames.  It makes you wonder why people can agree in the Lake Tahoe Basin, but not in Steamboat?

3. Trail Stewardship Act Funding

Here’s another recreation story about folks helping out with FS work this year, this time rafting.

Aherin, of Lewiston and Salmon, Idaho, owns Idaho River Adventures and is president of the Middle Fork Outfitters Association. During the chaos that followed the Trump administration’s decision to dismiss probationary federal employees, his organization worked with the Idaho congressional delegation to lay the groundwork for a solution.

The Middle Fork Outfitters Association has been using the Trail Stewardship Act to help the Forest Service maintain the roads that provide access to Boundary Creek. The 2016 law allows holders of special use permits to use the money they are required to pay the Forest Service (3% of their gross profits) for trail maintenance and to care for other recreational infrastructure.

Before the act, outfitters would write a check to the federal government. Now they can write checks to contractors who perform maintenance work and then use the receipts to offset what they owe the feds.

This summer, Aherin and other outfitters will divert the money they owe the Forest Service to the Selway Bitterroot Frank Church Foundation. In turn, the group will hire four people to work as checkers at put-ins and two to work on Forest Service river patrol crews.

“It is really in line with our mission, it’s just not something we have done before,” said Ryan Ghelfi, executive director of the foundation.

The group typically hires trail crews and wilderness rangers to help the agency care for the Selway-Bitterroot and Frank Church-River of No Return wilderness areas that overlay much of central Idaho’s backcountry. Working on the river is new and so far a temporary part of the group’s work.

Ghelfi said the people the foundation hires will work under the direction of the Forest Service and at least for now, it is just for this summer to help the agency deal with unexpected circumstances.

“The way things are right now, it’s something our organization needed to be able to say yes to and we did.

4. Moth Plan for Shoshone

Very interesting and comprehensive story from Wyofile on managing moth/grizzly tourism. Who knew there was moth/grizzly tourism? I try to avoid grizzlies, myself.

The Shoshone National Forest has been assessing its moth sites in consideration of management changes since 2015, when it completed its Forest Plan. Before that, around 15 years ago, Yellowstone region managers prioritizing grizzly bear issues identified the moth sites as a top-three issue in the ecosystem, U.S. Forest Service biologist Dan Tyers told the room in Cody.

5. FS and BLM Recreation in Wyoming Compared: BLM Not Having Problems

This is coverage of the Wyoming Outdoor Roundtable

The panel was part of the Wyoming Outdoor Recreation Summit, which gathered businesses, agencies and recreationists in Laramie to talk about issues like access and economic opportunities. Though Ashcroft and his fellow panelists discussed longstanding challenges, participants were keen to hear about recent DOGE impacts on Interior Department agencies like the U.S. Forest Service, Park Service and Bureau of Land Management.

“Is there going to be a hair-on-fire moment when the bathrooms aren’t getting cleaned and maybe the campgrounds are getting closed?” asked Wyoming Office of Outdoor Recreation Manager Mark Tesoro, who moderated the panel.

“One forest may have lost their entire special uses program, which impacts guiding and outfitters, where another forest may be whole in that region,” Ashcroft said. “So it truly is varying by district to district, forest to forest, that you’re going to see impacts.”

Regardless, he said, “the agency’s priority is to keep sites open, and so we are going to prioritize that to the extent possible.” Sites may, however, not be open at the same level of service that users have enjoyed in the past.

“There could be sites that historically had running water, that may not have running water,” he said. “There could be sites that had trash collection that may not have trash collection this year.”

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Trail maintenance will be a big challenge, Ashcroft added, so users could encounter more debris or downed trees.

Agency leadership wants to keep decision-making as local as possible, Ashcroft said, and has identified safety, fire, timber and recreation as priorities. “I see us trying to focus what we have on those priorities, recreation being one of those priorities.”

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Jennifer Fleuret McConchie, Wyoming BLM deputy state director and the third panelist, doesn’t think the federal challenges will prevent the BLM from getting its work done this season, she told the crowd.

Wyoming BLM staff, key to Trump’s “energy dominance” strategy, have been largely spared by DOGE. 

“I don’t think any of the challenges coming to face us this year are going to stretch our ability to meet those challenges and work with our partners to get the work done where it needs to be done,” Fleuret McConchie said.

Knowing what we know, I wonder why the FS would have more problems than the BLM.  Possibly because of the last Admin’s getting rid of temps for  this year, plus the FS having 5K or so probationary hires?  Or is it a budget thing? Certainly DOGE could tell a BLM minerals employee from a recreation employee. I’m guessing it might be more complicated than just “they have minerals there.”

Anyway, this might be a year to recreate on BLM sites preferentially.

 

CE Buffet: FS Adopts Other Agency CE’s

Part of the Fiscal Responsibility Act of 2023, agencies are allowed to adopt other agencies’ CEs.  I’m not sure these adoptions made it into the press, but I found them on the NEPA webpage.

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The Forest Service is pursuing adoption of categorial exclusions from other federal agencies on topics or areas where the Forest Service does not have existing directives. Adopting categorical exclusions increases efficiencies and eliminates the need to do work that has been completed by other federal agencies. Ultimately saving time and allowing for new work to be completed.

The Forest Service has published three adoption notices in the Federal Register resulting in the adoption of 44 new categorical exclusion categories.  These include a July 1, 2024, notice, a Sept. 27, 2024, notice, and a Nov. 8, 2024, notice.  In February 2025, the agency adopted 16 categories (PDF, 169 KB) related to disaster responses. In May 2025, the agency adopted three categories (PDF, 140 KB) related to plans and timber production.

Department of Commerce

  • Siting/construction/operation of microwave/radio communication towers less than 200 feet in height without guy wires on previously disturbed ground. (A-4).
  • Adding fiber optic cable to transmission structures or burying fiber optic cable in existing transmission line rights-of-way; (A-6).

National Oceanic and Atmospheric Administration

  • The disposal, demolition or removal of real property, buildings, and structures, including associated site restoration, and the disposal of personal property and debris. (F7)

Department of Energy

  • Construction, additions, and modifications to transmission facilities, new or existing powerlines, electric power substations and interconnection facilities. (B4.6B4.11B4.12B4.13)
  • Installation, modification, operation, or decommissioning of commercially available Solar photovoltaic systems (B5.16)
  • Electric vehicle charging stations; (B5.23)
  • Routine repair, preventative, and predictive maintenance activities, are required to maintain and preserve buildings, structures, infrastructures, and equipment in a condition suitable for a facility to be used for its designated purpose. Such maintenance may occur as a result of severe weather (such as hurricanes, floods, and tornados), wildfires, and other such events. (B1.3)
  • Repair, replacement, upgrading, rebuilding, or minor relocation of pipelines within existing rights-of-way, provided that the actions are in accordance with applicable requirements (such as Army Corps of Engineers permits under section 404 of the Clean Water Act). (B5.4)
  • Construction and subsequent operation of short (generally less than 20 miles in length) pipeline segments conveying materials between existing source facilities and existing receiving facilities (such as facilities for use, reuse, transportation, storage, and refining), provided that the pipeline segments are within previously disturbed or developed rights-of-way. (B5.5)

National Telecommunications and Information Administration

  • New construction or improvement of land, operations, or support facilities, fiber optics, and communication towers; (C-4 , C-5C-6C-7, and C-8)

Bureau of Indian Affairs

  • Utility installations along or across a transportation facility. (L.1) (.pdf – 700KB)
  • Activities involving remediation of hazardous waste sites if done in compliance with applicable federal laws such as the Resource Conservation and Recovery Act (P.L. 94-580), Comprehensive Environmental Response, Compensation, and Liability Act (P.L. 96-516) or Toxic Substances Control Act (P.L. 94-469). (K(2)) (PDF, 676 KB)

Bureau of Land Management

  • Disposal of mineral materials in amounts not exceeding 50,000 cubic yards or disturbing more than 5 acres, except in riparian areas. (F10) (PDF, 212 KB)
  • Granting and amending rights-of-way in existing or compatibly developed rights-of-way for facilities, utility service, or terminal access roads.  (E12E13E17) (PDF, 212 KB)
  • Placement and use of temporary portable corrals and water troughs. (D2) (PDF, 212 KB)
  • Emergency Stabilization actions in response to disaster events that threaten public health or safety, property, and/or natural and cultural resources, and are necessary to repair or improve lands unlikely to recover. (CE I1) (PDF, 212 KB)

National Park Service

  • Changes or amendments to an approved plan when changes would cause no or only minimal environmental impact. (12.5 B (1)) (PDF, 212 KB)

U.S. Fish and Wildlife Service

  • The construction of new, or the addition of, small structures or improvements for the restoration of wetland, riparian, instream, or native habitats, which result in no or only minor changes in the use of the affected local area. (B(3))
  • The reintroduction or supplementation (e.g., stocking) of native, formerly native, or established species into suitable habitat within their historic or established range, where no or negligible environmental disturbances are anticipated. (B(6))

United States Geological Survey

  • Collection of data and samples, and test or exploration drilling or trenching (B, G, L) (PDF, 145 KB).
  • Establishment and/or operation of survey marks, field instruments, and research/monitoring devices (H) (PDF, 145 KB).
  • Off-road travel or minor activities to gain or prepare access to sites (K, P) (PDF, 145 KB).

Federal Highway Association

  • Emergency repair, restoration, retrofitting, or replacement actions for transportation facilities damaged by an incident resulting in an emergency declared that is in operation or under construction when the incident occurred. (C9)

Farm Service Agency

  • Construction or ground disturbance actions. (E2)

Natural Resource Conservation Service

  • Planting appropriate herbaceous and woody vegetation on disturbed sites to restore and maintain the sites ecological functions and services. (d(1))
  • Replacing and repairing existing culverts, grade stabilization, and water control structures and other small structures that were damaged by natural disasters. (d(4))
  • Removing storm debris and sediment following a natural disaster where there is a continuing and eminent threat to public health or safety, property, and natural and cultural resources and removal is necessary to restore lands to pre-disaster conditions. (d(7))
  • Stabilizing stream banks and associated structures to reduce erosion through bioengineering techniques following a natural disaster to restore pre-disaster conditions to the extent practicable, e.g., utilization of living and nonliving plant materials in combination with natural and synthetic support materials. (d(8))
  • Restoring an ecosystem, fish and wildlife habitat, biotic community, or population of living resources to a determinable pre-impact condition. (d(11))
  • Repairing or maintenance of existing constructed fish passageways, such as fish ladders or spawning areas impacted by natural disasters or human alteration (d(12))

Tennessee Valley Authority

  • Actions to maintain, restore, or enhance terrestrial ecosystems that generally involve physical disturbance of no more than 125 acres. (CE 30)
  • Forest management activities to manipulate species composition and age class or regenerate forest stands up to 125 acres and requiring no more than 1 mile of temporary or seasonal permanent road construction and Salvage of dead and/or dying trees up to 250 acres and requiring no more than 1 mile of temporary or seasonal permanent road construction. (CE 31)

An appeal or objection is a formal request to a higher agency authority for review of an environmental document or decision. The pre-decisional objection process provides the public an opportunity for administrative review of unresolved public concerns over a proposed decision. The public’s rights and responsibilities to file an objection are defined at 36 CFR 218 for projects and activities documented in an environmental assessment or environmental impact statement, and at 36 CFR 219 for land management plan amendments and revisions

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I’m not sure why the appeal and objections processes are listed, as I didn’t think they applied to CEs?

Forest Service Web Modernization

We’ll be seeing fewer of these 404 pages..

From this site
Thanks to all the folks who worked on this! Web and IT are among the less obvious but critical folks in the agency.

Note: since my original post, I have heard some forest concerns about how these changes are working, which are in the comments below.

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If you use our agency forest, grassland and regional websites, you’ll have noticed a recent change. As part of an overarching effort to improve the public’s digital experience, we have migrated our websites to a new content management system. What does that mean?

It means that we’re going to have a whole-of-agency approach to website design and management. Visitors will be able to find the same kind of information under the same topics across all forest websites. The web is our virtual first impression. It’s where visitors meet our forests and grasslands, and it should be welcoming, easy to navigate and clearly demonstrate the services and value we provide to the American people. The most obvious shift is in our menu: Rather than basing our website on our internal organizational structure, the menu is topic-based, a design that was developed based on data and with the public in mind.

This web migration is a strategic overhaul that ensures our digital presence aligns with current trends, technology and federal mandates. It meets user expectations for modern web presence, providing consistency and improving agency efficiency.

By eliminating reliance on outdated, licensed technology and uniting the agency under a single, efficient cloud environment, this migration delivers more than $1 million in annual cost savings and redeems our fiduciary responsibility to the American public. It has allowed us to systematically review our content and remove redundant, outdated and obsolete information while preserving our records. We are ensuring that links work, photos are appropriately captioned, and accurate information is readily available.

These changes benefit you as well. The streamlined approach will make it easier to provide up-to-date information. Web contributors will be able to edit content more easily without needing extensive coding skills, and publishers will be able to push updates with the click of a button.

You will notice that not all content has moved. We have thousands of webpages across the internet, so we ask you to be patient as we continue to bring pages online. If you have any questions or concerns, contact your region or station web manager for assistance.

This has been a significant undertaking that required support from across the agency. Our webmasters, web contributors, data specialists, public affairs staff, developers, and many others have been working in the background to deliver these improvements. I thank the teams that tested processes and links, identified what worked and what needed to be improved, and dove into the details to make sure the old systems talked to the new systems. And I especially thank those who took leading roles in this effort: Mason Lowery for his oversight; Joey Jones and Rob Herring from CIO; regional web team members Joe Banegas, Cyndee Maki, Chase Martin, Kelsey McCartney, Witne Neil, Kate Salm, Michelle Tegan, and Sean Tullis; and those who led the project: Kari Boyd-Peak and Linda Harms.

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The folks at the FS also gave me a contact name for those of you who find broken links.. in the past, I know that’s been difficult. The address is SM.FS.webmaster at usda.gov

FSEEE Files Case Against Retardants, This Time Based on ESA

Another fire season, another fire retardant case

I can’t remember if this is the third time; there was the “Mark Rey going to jail” case, and a more recent case (that maybe led to the NPDES permit requirement? Whatever happened to that?)
But maybe some went by when I wasn’t paying attention.

I first heard about this from The Hotshot Wakeup last weekend. According to his industry sources, the USC study (cited in the case, apparently) involved formulations that are no longer used.

I asked Andy why just the FS and not other wildfire agencies. Here’s his answer:

Contracting for all federal leases of aerial retardant aircraft is done by the FS. The FS also controls retardant formulation approvals through its Qualified Product List.

Here’s a link to the Missoulian article.

Here’s a copy of the complaint, thanks to Andy for sending!

That’s all I know..

Here’s a few related question for experts that I’ve never heard answered..
When Senator Sheehy wants only one federal agency (FAA, I guess) to check planes and not the FS, what does the FS check that’s different? It seems like that would be good to know, but I don’t see that in the stories. Also, I had heard that some new formulation, supposed to be more gentle to the environment, had negative impacts to the interior of aircraft, which raised questions about the FS adequately checking on that… but never heard the rest of the story.

The Once and Future Forest Service: Land-Management Policies and Politics in Contemporary America: Char Miller

Reorganization and spring are in the air.. and so Char Miller was kind enough to offer his thoughts (on reorganization). I also asked him to write about how his thoughts have changed, or not, since he wrote the original Journal of Policy History piece in 2009, and the revision for 193 Million Acres in 2018. First, here’s his introduction from today (2025)

At the heart of this essay—which appeared first in the Journal of Policy History (2009) and was revised for Steve Wilent, ed. 193 Million Acres (SAF 2018)—lies what is now a quaint set of assumptions. That whatever transformations might occur in the structure and mission of the US Forest Service, that they would be devised in collaboration with Congress, in consultation with a wide array of interest groups, and abide by then-current federal laws. There were, I thought, sturdy guardrails in place that, regardless of the structural changes, would ensure the continued stewardship of the national forests, wildernesses, and grasslands. Since January 20 th , those assumptions have been blown to pieces. This administration’s dismantling of the agency’s capacities has been disturbingly intense—the firing of hundreds of employees, the retirement (forced or voluntary) of hundreds more, has left the Forest Service bereft of rangers, supervisors, and directors. Their departure is by design, of course: without staff, the agency cannot enforce the laws its public servants swore to uphold (and did). Absent these principled individuals, the administration seems poised to off-load federal lands to the states (see Martin Nie’s brilliant discussion of this threat in The Smokey Wire, April 21, 2025); or let them be picked apart by private interests (as an example, see David Mertz’s discussion of the Maude family case in The Smokey Wire, May 7, 2025).

So, if you’d like to step outside of the current (and cynical) chaos, and contextualize it by reading how the Forest Service has evolved over time and how change might have occurred in a more transparent, consultative, and democratic fashion, read on.

Here’s a link to the original piece in the Journal of Policy History.

As I did yesterday, I’ll pick some pieces out from the 2009 paper that I find interesting, which might not be yours, so feel free to comment on anything in the paper.

Scenario One: Evolutionary Dynamics

Since these laws were adopted, the agency has appeared to be wandering in the forest. Pounded in federal court, faced with drastic budget cuts and sharp reductions in personnel, it has struggled to find its way, leading one former chief to argue that it is mired in “analysis paralysis,” a logjam preventing it from doing its proper work. Complicating this struggle to define its contemporary mission has been steep declines in timber harvests, escalating population pressures along the urban-wildland interface, increased recreational use, intensifying forest fires, and serious water-management issues.

No wonder the agency’s morale is low. 10

The footnote goes to 10. Jack Ward Thomas, “What Now? From a Former Forest Service Chief,” in A Vision for the Forest Service: Goals for Its Next Century, ed. Roger Sedjo (Washington, D.C., 2000), 10–43; Char Miller, “Identity Crisis,” Forest Magazine, Winter 2008, 44–47. I don’t recall my morale being low in 2009, and if it had been low, it would have been more about irritating supervisors or employees, byzantine hiring practices, and inscrutable computer applications, and not so much about an agency identity crisis. But that’s just me.

And “analysis paralysis” was actually part of a broader social tendency, which we find in articles about “why we can’t build things” and similar topics.  Although when we worked on it (I was the NEPA person on the Process Predicament team) we never thought ourselves as part of a larger societal movement. For example in the recent discussions of Abundance by Brink Lindsey (April 25, 2025 to be exact:

The irony, as Klein and Thompson point out repeatedly, is that this new progressivism has ended up empowering an especially hidebound kind of conservatism: an enervating “procedure fetish” within government, combined with a hydra-head “vetocracy” outside. This combination has saddled us with a woefully underperforming public sector generally, and an especially profound disability with respect to any project involving the large-scale rearrangement of atoms in the physical world.

The FS was talking about this in the 90’s, but no one was listening. The change that I see is that due to climate change mitigation, different and more important folks want to rearrange atoms.

Scenario Two: Devolutionary Process:

Indeed, a proposed alteration that the Forest Service has faced—and to date has fended off —is the devolution of its lands and authority to the individual states in which its forests and grasslands are located.

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Much more plausible are calls for the creation of a cooperative conservation strategy in which local groups and federal land managers together develop forest plans. Th is has a historical basis, too: Circular 21 (1898), which promoted the agency’s cooperation with private landowners, found its analogue in other initiatives that encouraged forest rangers to discuss with local communities and economic interests how best to manage the forests. More recently, cooperative actions have been nurtured by the National Forest Management Act and the Endangered Species Act, which require public participation and interagency coordination. They have also been energized by community environmental initiatives promoted at the 1997 Seventh American Forest Congress. Bolstered by university-sponsored think-tanks,such as the Public Policy Research Institute at the University of Montana, they have launched several successful ventures, including the Quincy Library Group (1992) and the New Ranch program developed by the Quivira Coaltion (1997). The latter seeks to operate within what it calls the “radical center—a neutral place where people could explore their interests instead of argue their positions—and at the grassroots, literally the ‘grass’ and the ‘roots,’ where, we believed, trust needed to be built anew.” 16 The “Lubrecht Conversations,” held outside Missoula, Montana, in 1998, shared this commitment to a “bottom-up” approach to national-policy reform. Local consensus management would evolve to include wider water-shed and bioregional perspectives that then would shape the national agenda.

Most captivating was the group’s call for the creation of a “virtual” Region 7 within the Forest Service wherein districts and forests would propose “to develop practical collaborative decision-making processes at the local/regional level, which might eventually evolve into a national restatement of basic mission.” If acceptable, the Forest Service would fund the experiment but would not retain authority over its design or implementation. 17

Although to date “Region 7” remains but a tantalizing idea, other experimental formats have been enacted. One on-the-ground example is the Valles Caldera Trust (2000), a government-owned entity that provides management and administrative services for the Valles Caldera National Preserve in northern New Mexico. This national preserve suggests the array of options that have been emerging in timber towns and ranch country in response to decades of political discord, legal wrangling, and bureaucratic entanglement.
This development received another push in August 2005, when the White House Conference on Cooperative Conservation convened, a sign that community-oriented, collaborative conservation has captured considerable political interest and generated significant momentum. 18

I thought all this was interesting because it makes me wonder what happened to those groups? QLG, Quivera, Valles Caldera? And if Collaborative Conservation was a thing in 2005, how did we end up with the recent Rock Springs RMP, Lava Ridge Wind Project (granted those were BLM, and therefore more overtly/organizationally political). Are “bottom-up” efforts to some extent overwhelmed by national partisan political inclinations and the wills of key Admin allies?

Scenario Three: Revolutionary Impulse

The creation of a new Department of Conservation in the executive branch, by contrast, would expand the federal managerial presence and its regulatory authority. With a seat in the cabinet, this department would house the nation’s most important land-management agencies—the Bureau of Land Management, the Bureau of Reclamation, the Fish and Wildlife Service, the Forest Service, the Geological Survey, the National Resources Conservation Service, and the National Park Service, among other entities. By creating economies of scale and greater efficiencies of action, this new department would save money and would serve as a standard bearer for the modern environmental movement.

Miller has a history of related efforts on pages 98-99

Despite the failure of these various presidents to create a conservation superagency, there are signs that an integration of agency function is under way. In 1997, Congress authorized a program called Service First: Working Together, in which the Forest Service and the Bureau of Land Management were authorized to merge various functions. One such joint venture is the Durango Public Lands Center. Th rough it, the two agencies manage their lands in southwestern Colorado. Th e leadership of the San Juan National Forest and the San Juan Field BLM Office, like the twelve-person staff , is “cross delegated.” Because each employee is responsible for “all aspects of the two agencies’ work and is equally responsible to the USFS Regional Forester and BLM State Director,” because each is required to be fluent in both agencies’ statutory regulations and wears the two uniforms, this is an innovative, even unusual, arrangement. The San Juan is “the only organization in the country with a single team providing leadership in all aspects of land management and public service for the two federal agencies.” 23

These interchanges are part of a larger attempt to merge scarce skills and resources among the nation’s land-management agencies. Forest policy expert

Sally K. Fairfax has argued that more should be done to facilitate the convergence of the identities and missions of these agencies. Noting that “the historic distinctions and feuds” between the Forest Service, the National Park Service, and the Bureau of Land Management “no longer matter,” she observes: “The hostility between the advocates of forest reserves and park reserves that began before either agency was formed conceals the fact that for most of their existence, they have been more alike than not. As timber fades as a Forest Service preoccupation, and recreation emerges as dominant [in] present and future concerns, the justifications for having multiple and distinct federal management agencies fade as well.” 24

The often-prescient Fairfax said this in 2005. Of course, both BLM and the FS have fuel management as goals, and BLM has the additional responsibility for minerals.. but still her views seem eminently reasonable.

Lending further credence to her argument is a November 2006 Memorandum of Understanding that the Bureau of Land Management and the Forest Service signed in partnership with the Fish and Wildlife Service and the National Park Service. It committed the four agencies “to carry out shared or joint management activities to achieve mutually beneficial resource management goals.” Service First authority has been utilized primarily for merging offices, issuing joint permits, sharing management, and creating single points of contact for resource programs. Given the patchwork of lands each agency manages and the proximity of their holdings, this integrative approach makes considerable sense, so much so that the Bureau of Indian Affairs, the Bureau of Reclamation, and the Army Corps of Engineers are considering seeking Service First authorization. In this incremental fashion, the dream of a Department of Conservation that has eluded several presidents.

Whatever happened to Service First? Often critics of rapid change will argue that change should occur slowly, but organizational antibodies tend to react strongly to change. For example, I was told by a knowledgeable person that the San Juan experiment was stopped by one State Director. I found this hard to believe, but organizations survive, I guess due to their strong immune systems.

I should note here that the alignment of the Dept of Conservation is not the same as moving the FS to Interior and not the same as “one Wildfire Agency”.  Still it gives us the picture of the long-term signal versus any individual reorganizational effort.

From Miller’s summary:

Separately, none of the three scenarios sketched out here—evolution, devolution, revolution—will have much chance of redefining the Forest Service’s twenty-first century structure or its guiding perspectives. None of these possibilities will be achieved without reference to or in combination with the others. Moreover, although any change in the agency’s land-management mission will require internal support from the leadership and staff of the Forest Service, the real locus of any such transformation lies in Congress and the executive branch.

But of course many structures can support the same mission.  What do you think?

Grassroots Wildland Firefighters on National Wildland Fire Service Proposal

I’d like to post a big thank-you, both to Kelly Martin and to Riva Duncan of Grassroots Wildland Firefighters.   Some have accused this thinking as being a creature of the current Admin, which we know would be a death-knell for a policy position from the perspective of any person who has correct thinking (just kidding), but as with so many issues, it’s more complicated than that.

It seems to me that we live in a world where everything is connected, and yet organizations can’t handle everything.  So there need to be divisions.  Think NRCS and FS State and Private, both deal with private landowners, one with all plants, and one with trees.  Plus there’s NIFA Forest Extension to give technical advice. So the agencies are kind of organized by topic (trees) and kind of organized by landowners (targets of policies).  My point being that there will always be organizational hinges or links, that work better or worse, for individuals, inside and outside government, to negotiate.  And folks interested in making government work better try to  a) ensure that the hinges are not hindrances (by organizational design)  and b) oil the hinges that squeak.

Just to back up, Megafire Action, which has ties to D’s,  calls for one department and moving FS to Interior,  from their report.

The Fit for Purpose Wildfire Readiness Act of 2025 marks the new beginning of a broad discussion among Congress, federal agencies, firefighters, land managers, Tribes, and forestry/wildfire policy groups on how to best modernize and streamline federal wildland fire mitigation and management. The bill directs the Secretaries of Agriculture and Interior submit a plan with three primary elements—

  1. a budget for the National Wildland Firefighting Service;
  2. a description of the qualifications required for an individual to be appointed to be the Director of the National Wildland Firefighting Service, who shall be appointed by the President, by and with the advice and consent of the Senate; and
  3. a description of the resources and authorities necessary to consolidate Federal wildland fire response efforts of the Secretaries in the National Wildland Firefighting Service.

The plan that comes out of this process will require careful coordination and input from all stakeholders. For nearly a year, Megafire Action has been researching past proposals to reorganize and improve the federal wildland fire response. Our assessment has included proposals to relocate the Forest Service under DOI and the creation of a “National Wildland Firefighting Service’’ as envisioned by Senators Sheehy and Padilla.

Note also that the Fit for Purpose Wildfire Readiness Act is bipartisan.  So the idea long predates this Admin.

Now let’s listen to what Riva is saying; I’m with her when she says “we (GWF) know we don’t have all the answers or necessarily the “right” answers, but we do believe the time is right for a real discussion” :

Grassroots Wildland Firefighters (GWF) has had a National Wildfire Service as one of our Four Pillars since the organizations establishment in 2019. We released our proposal shortly after the introduction of the Sheehy/Padilla Bill, but it was lost in a lot of the administration’s chaos at that time. Like the discussion about a NWFS in DOI, and several comments here, a separate agency doesn’t automatically divorce fire suppression from mitigation, ecosystem health, or the land management agencies, nor does it discard the collateral duty workforce (always hated the word “militia” to describe our non-primary fire employees). Ours certainly does not. Also, we (GWF) know we don’t have all the answers or necessarily the “right” answers, but we do believe the time is right for a real discussion. GWF exists in order to represent the boots on the ground and those that directly support them, and that will always be our priority — and something that has been absent in all the other discussions. Our argument has always been that the status quo no longer serves the firefighters. The agencies have failed to protect the workforce, and it’s time to not only think about how we must be able to serve our publics AND our public lands, but also how to serve the people doing the work in an ever riskier and more demanding profession. For those who care to read our proposal, you can do so here: https://static1.squarespace.com/static/5f6ced5b8d33bb20b5c97c0b/t/67a964eb7f17585b0fd3fdf5/1739154668441/GWF+National+Wildland+Fire+Service.pdf

Let’s dig into the GWF report a bit. I recommend reading the whole paper, because I’m not a fire person and what was interesting to me might not be to you and vice versa. Based on the citations, the report was developed since 2023, but Riva can tell us exactly when.

It is past time to build and implement a National Wildland Fire Service (NWFS). For decades, the US Forest Service and Department of Interior (DOI) have refused to do any kind of study or white paper to look at the pros and cons of removing wildland fire, fuels, and aviation response/management from the natural resource agencies. Any serious requests or suggestions have been met with disdain and refusal to even consider such an exercise. Now the FS and DOI struggle to retain experienced wildland firefighters, managers, and support staff such as dispatchers. While the rest of the non-fire workforce is faced with hiring “pauses” and plummeting program budgets, removing fire from these agencies is not only necessary to efficiently address the wildland fire situation, but it just may “save” the rest of the FS and DOI agencies.

 

Background
The current system of five federal agencies (US Forest Service, Bureau of Land Management, the National Park Service, the US Fish and Wildlife Service, and the Bureau of Indian Affairs) under two different departments (USDA and DOI) being tasked with responding to wildland fires on federal lands (and assist cooperators) is extremely inefficient. This is largely due to the fact that while the employees across the agencies essentially do the same jobs, the agencies have different budgets, position descriptions, training standards, payment processing systems, health support programs to only name a few. Even the four agencies within the DOI have numerous inefficiencies and redundancies between them. Wildland firefighters move between agencies regularly, and, when they do, they have to deal with discrepancies in position descriptions, training standards, background checks, HR issues, etc. After the passage of the Bipartisan Infrastructure Law and the mandate for the FS and DOI to change to a new federal job series, the DOI agencies re-graded Interagency Hotshot Crew (IHC) Superintendents at the GS-10 level, while the FS kept these critical positions at the GS-09 level. It is the exact same job. These inefficiencies and duplications are confusing even to those within the agencies and are costing the American taxpayers.

What I hear is “the status quo is not working for us people doing the work.” We can imagine another solution.. “fix those interagency problems without reorganizing” and yet, no one, over all these years, has seemed to be very interested in oiling these particular hinges. So it is not surprising that the workers want to place the hinges elsewhere in the hope that someone else will have to deal with them.

There is a very interesting, and somewhat depressing, review of the National Fire Plan and associated history since the year 2000 starting on page 4. It even cites a report by Michael Rains (frequent TSW contributor) and Jim Hubbard.

Why was FPA never actually implemented? According to 2016 Denver Post interviews with original developers and the Chief of the Forest Service at the time, it came down to the fact that FPA showed that the most efficient way to manage resources and budgets was to shift resources, and therefore funds, from places with less wildfire activity to places with more. The team lead said that initial version took agencies’ objectives and then optimized them to determine how to best allocate resources for the greatest impact. The idea was to figure out how much money to devote to fire suppression and to reducing fuels to improve overall forest health, and where to do it. But when the tool was used for a preliminary analysis in 2006, not everyone liked what it found. The results showed which areas needed more resources and which needed less, throwing into uncertainty budgets used for staff programs and some administrative overhead. Forest Service officials began to publicly cast doubts about the efficacy of FPA, but Douglas Rideout, the CSU wildland-fire economist and researcher, defended the methodology behind the original FPA, noting it passed a peer review published in a scientific journal the year prior. The Former team leader on the project said FPA became a shadow of what it was supposed to be, the victim of forces opposed to a process that would take decisions about where to put resources out of their hands (Olinger and Gorski, 2016). To this date, no other fire planning analysis tool has been developed for implementation.

Neither department, USDA nor DOI, have any current data on the appropriate numbers, mix, and locations of federal wildland firefighting resources. They continue to cling to what has become an arbitrary number of approximately 14,000-16,000 firefighters. None of the federal agencies have developed a modern formula for determining how many wildland firefighters and support personnel are truly needed to address 21st century issues. It can be done. The California Department of Forestry and Fire Protection (CALFIRE) has one and bases its staffing and funding from it. Many municipal fire departments in California have similar formulas.

My experience was with a GAO review that suggested that beltway-bandit- generated models would be better at determining allocations. Peer review is great, but people have fears and if those fears are not dealt with directly, telling them that something about budget allocation is “scientific” is not particularly helpful.  When resources don’t come, “the AI told us that optimal allocation was for someone else” will not make people feel better.  And undersecretaries will probably still order air tankers to Long Island.  Still, an interesting question.. how did CALFIRE successfully do it?

There’s a strong concern about background of people deciding about wildfires.

Historically, before promoting into these positions, people worked their way up through the agencies in forestry, engineering, biology, range, and wildland fire positions. They spent years as field-going employees and then mid-level managers before moving into positions such as District Ranger, District Manager, Park Superintendent, Refuge Manager, etc. Many had fought fire early in their careers. However, over the past 15 or so years there has been a significant push to hire people from non-traditional programs or even from outside the natural resource agencies. A by-product of this shift is that the average age of a District Ranger in the FS has dropped dramatically, which means people holding those positions are at earlier stages in their career instead of later. We can argue that most now don’t bring fire experience into these jobs, but what is also alarming is many bring little work experience of any kind as they come from special placement programs such as the Presidential Management Fellow program (very popular in the FS) after graduate school. The FS is placing numerous people from this program into line officer positions on national forests with large, complex fire programs.

What this really means is that individuals with no fire education or experience are being tasked with making extremely critical decisions about wildfire within their jurisdictions. Decisions that could have catastrophic results. The situation has gotten so dire that the federal agencies developed an accelerated fire management training program for people in these positions.
However, rather than competency, the goal seems to be rapid certification, which does nothing to resolve the issue. These agency administrators oversee wildfire incident commanders, which is unsettling. Much like if someone with only a basic first aid class were put in charge of a hospital’s emergency department.

My bold.  That’s a pretty strong statement, but it’s very clear about their concerns.

What this has meant is individuals with the ultimate wildfire decision-making authority have put wildland firefighters, and often the public, in harm’s way, by making poor and/or uniformed decisions. These are not usually malicious actions, but typically come from places of ignorance, inexperience, incompetence, or fear of torpedoing their young careers. This also means that line officers can “hold” resources back from critical suppression needs. It is common for some line officers to cancel suppression resources’ availability to assist other regions when those requesting regions are experience high fire activity.

I first heard these concerns at the Retirees Roundup in Vail in 2012. When the retirees expressed concerns about the fire experience of line officers, I felt like the FS was saying “this is the way it’s got to be, so we’re doing the best we can with more training.” As to holding resources back, of course people are worried about how decisions are made to use resources. That’s why States like Colorado and California are buying their own.

Cure Your PERC-o-Phobia? A Round-up of Their Current Work

Some projects of the PERC innovation lab.

 

Thanks to the folks at PERC for giving us this round-up of what they’re currently working on.

Each of us can pick and choose what positions of theirs they support.  I like their views on voluntary conservation efforts and “pay to protect.”  Also I support charging international visitors more to visit taxpayer-supported National Parks. And anyone who takes on Wild Horse and Burro policy voluntarily deserves some credit. I would think almost everyone would find one PERC position that they can support.. PERC supports conservation leasing, a priority for the last (D) Admin, so it seems they are generally libertarian/free market regardless of political party.  My general view is that if folks can work things out (making peace) by exchanging funds (not taxpayers’ funds) isn’t that better than court cases, competing op-eds, attorneys’ fees, and ultimately somewhat random outcomes, appeals and so on?

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On National Parks: By empowering outdoor recreationists and visitors to take a more direct role in the care and maintenance of our national parks and other public lands, PERC believes we can make these treasured places less reliant on the whims of political funding decisions and ensure they are well taken care of for generations to come.

On private land conservation/virtual fencing: PERC is excited to explore the conservation potential of virtual fencing technology. Traditional barbed wire presents a challenge for wildlife, whose migration depends on unobstructed and expansive landscapes. Virtual fencing technology can help open migration pathways and restore sensitive habitats without sacrificing a ranch’s financial viability.

On wildlife conservation and the ESA: The presence of certain species on private lands can impose significant costs on landowners, such as forage loss and depredation, or burdensome environmental regulations that limit land use. As a result, private landowners often view wildlife as a liability to be avoided instead of an asset to be protected. And because most species depend on private lands for habitat, these negative incentives can adversely impact wildlife. PERC seeks to increase ESA recovery rates by making wildlife an asset rather than a liability and giving private citizens clear incentives to invest in habitat conservation.

On forest health and wildfire mitigation: A century of fire suppression has disrupted natural fire cycles and impaired forest health, leading to the crisis of catastrophic wildfires we experience today. To reverse these trends and foster more resilient forests, we must increase the pace and scale of active forest management. Prescribed fire and mechanical thinning are two essential tools in the forester’s toolbox, but expanding the use of these tools on both public and private lands is often hamstrung by overlapping regulations, litigation, and inadequate funding. By reducing existing regulatory hurdles and finding more creative funding approaches, we can fix America’s forests.

On the wildhorse crisis: PERC research helped innovate the Bureau of Land Management’s Wild Horse and Burro Adoption Incentive Program, which has successfully increased adoptions of wild horses from BLM holding facilities. PERC believes that such tools are critical to alleviating the wild horse overpopulation crisis on our public lands and improving the ecological health of our public rangelands.

On public lands/conservation leasing: Conservation is a legitimate use of public lands that people should be empowered to pursue. PERC believes a better, market-based approach to federal land leasing would allow competing groups to negotiate with or bid against each other to determine which use has more value to prospective leaseholders, whether that be traditional uses like mining or grazing or new uses like conservation or restoration.

Solutions to Restore the Great Salt Lake: PERC is actively working with Utah’s Great Salt Lake Commissioner’s Office to help find sustainable solutions to restore the lake. A recent report explores the potential of voluntary water leasing.

Bob B. on National Wildland Fire Agency: Observations and Suggestions

Bob B. has obviously been doing a great deal of thinking about this.. it was originally a comment,  but his ideas are extensive and worthy of discussion on their own.

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An opening thought to this post…“People don’t resist change. They resist being changed.” — Peter Senge

Maybe it’s time—because the status quo in federal wildfire management is unsustainable. As someone who’s worked at every national, regional, and forest levels of the U.S. Forest Service—I’ve seen firsthand how fragmentation, underfunding, and outdated models are limiting our ability to meet today’s megafire challenges.

Here are some thoughts to inform the conversation around a potential executive order or legislative reorganization:

If We’re Doing This—What Should the Organizational Model Be?
If we move forward with establishing a National Wildland Fire Agency, the organizational model will determine its success or failure. Two analogies offer insight:

• DHS Post-9/11 shows how consolidating multiple agencies under one mission can increase national focus—but also demonstrates the pitfalls of poor integration, such as clashing agency cultures, unclear roles, and persistent stovepipes.

• The U.S. Space Force, with a workforce similar in size (~10–12K), is a better analogy. It was built with clarity of mission, streamlined command, and intentional structure. A National Wildland Fire Agency should emulate Space Force’s lean, agile design while learning from DHS’s growing pains.

• Any other ones to copy?

Integrating Prescribed Fire and Suppression
Suppression and prescribed fire are typically executed by many of the same people—yet fire “years” make that untenable in the future. Consolidating these functions under the new agency would improve operational alignment and reduce risk. Land management agencies could contract back for prescribed fire work, but the staffing of resources and accountability would rest with the wildfire agency. This shift could finally address chronic under-resourcing and reduce the unacceptable rate of escaped prescribed burns.

Unified and Interoperable Data Systems
Current systems are fractured, especially between USDA and DOI. During my time, I saw how even basic functions—like syncing global address books—failed across agencies DOI and USFS in the same building. All dispatch centers and platforms (like IROC) should be unified under the new agency to ensure full interoperability and operational clarity.

Facilities Optimization
Many current agency facilities are obsolete or redundant. In Region 5, it was documented that the USFS had as many facilities as employees, most in poor condition. A BRAC-style review is needed to determine which facilities will transition to the new agency. Some former DOD sites (like March AFB) could be rehabilitated for training and housing, so long as they’re affordable and family-suitable.

National Performance Metrics and Procurement
A unified agency would allow for standardized staffing, equipment, and operational benchmarks. Dare I utter national “standard module configuration”. Right now, the same type of engine or crew is staffed and equipped differently depending on the forest or region. Using Defense Logistics Agency (DLA) procurement processes could streamline purchasing and improve readiness. Finally, just like DOD assigns mission sets, equipment, and training without units worrying about base budget funding.

Permanent Incident Management Teams (IMTs)
Permanent, nationally managed IMTs would ensure consistent training, readiness, and response capacity. Building on the USFS NIMO model, these teams would retain control of operations, finance, and intelligence throughout an incident. Supported agencies (e.g., USFS, NPS, BLM) would no longer pull the response in multiple directions, the new agency would own the mission, data, and accountability. This would also increase suppression cost analytics (why is that fire so expensive?), which is always asked the farther you are from the fireline.

Law Enforcement, Arson Investigators and Lawyers For Cost Recovery
LE personnel in USFS (maybe other agencies) operate using fire-funded systems (dispatch, radios, etc.), but without formal alignment. Under a new model, LE support shouldn’t be expected and should be contracted by an agency to the wildfire agency. Cause/origin investigations will roll to the new agency with a centralized investigative unit, modeled on CAL FIRE’s approach, could recover hundreds of millions annually through arson-related litigation, and ensure those cases hold up in court.

Finally, Arson Investigation Coordination and Information Sharing. Read this and then think about what an agency needs to be to deal with this looming threat. Reference: National Counterterrorism Center. (n.d.). Mitigating the Threat of Terrorist-Initiated Arson Attacks on Wildland-Urban Interface Areas. https://www.dni.gov/files/NCTC/documents/jcat/firstresponderstoolbox/124s_-_Mitigating_the_Threat_of_Terrorist-Initiated_Arson_Attacks_on_Wildland-Urban_Interface_Areas.pdf

We must close the gap between local cause and origin and national arson tracking. The unified Wildland Fire service should participate in the Information Sharing Environment (ISE) via the National Network of Fusion Centers to look multi-jurisdictionally at arson. The ATF’s Bomb Arson Tracking System (BATS) should be the standard platform for all investigative reporting, enabling broader threat analysis and interagency response coordination.

“Change is disturbing when it is done to us, exhilarating when it is done by us.” Rosabeth Moss Kanter (Harvard Business School)
While the change may be hard, a unified National Wildland Fire Agency offers a rare opportunity to reset—this time, with clarity, coordination, and mission alignment.