This essay was sent to us by a long-time US Forest Service employee in response to comments I made yesterday on the Lookout Livestream. It addresses some of the structural problems crippling the US Forest Service, and provides their perspective on major changes they experienced across their career on the Lassen National Forest, in Northern California.
8/6/2024
While I certainly would agree that NEPA, like probably any government process, can be streamlined, I also believe that NEPA has become a scapegoat to direct attention away from more fundamental issues within the agency.
The reason I feel this way is that I know how productive the Lassen was during the Quincy Library Group (QLG) period. Forest employees were working their asses off trying to meet annual targets that were legislated to meet, but the morale was high and the Forest was productive, much more productive than now.
(Editor’s note: The QLG was a collaborative planning effort between Plumas County environmental groups and the timber industry which resulted in the Herger-Feinstein Quincy Library Group legislation which authorized a lot of thinning and logging on the Lassen, Plumas, and Tahoe National Forests, in the 1990s. The majority of the QLG’s work was never implemented because (in part) national environmental groups didn’t like the concept of local control of public forest lands, and successfully sued to stop the work.)
During QLG the Forest had the same NEPA rules that exist today. During QLG the Forest had the same group of FS Sensitive species and similar Listed species that we do today. Despite those rules, the same rules that are in place today, the Forest was productive.
And, compared to now, during QLG there was much greater complexity in Forest Plan direction. In 1999 the QLG EIS amended the Lassen’s Forest Plan, and then the Plan was again amended by the 2001 ROD, and then again when the 2004 ROD replaced the 2001. Three amendments in five years that created three overlapping and changing sets of direction that, if you hadn’t been an employee when the changes in directions happened, were confusing to navigate through. But, despite more complex direction than today, the Forest was productive.
The LNF was recently producing about a third less timber volume than during the QLG period, and it may be producing less than that now. So, how could the Forest be much more productive during QLG than now, when during QLG there were the same rules associated w NEPA, the same rules associated with Sensitive species, and more complex rules associated with Forest Plan direction?
Contrasting the current situation with that during QLG, it’s not the rules of the game, like those associated with NEPA, that matter the most, but it is how leadership, and employees, choose to play the game, as well as the number of players available. When I first started it was near the end of ‘timber as king’ within the agency. But, no matter what anyone thinks of how much volume was being harvested or how it was being harvested at the time, it’s important to point out that the employees at the time were very good at what they were doing, most had a lot of experience in their jobs and had a lot of time spent on their chosen district, and they were very professional and motivated to do the work, and Districts were well staffed. During QLG, many of that same generation were still present. New employees coming in during that era of the late 1980s or into the 1990s were caught up in the energy, the professionalism and the commitment to the job, and they saw that leadership held Forests accountable to meet targets and Forests in turn held employees accountable, and employees held themselves accountable to fulfill their responsibility in the planning and implementation processes, and that energy and motivation and accountability carried thru QLG. That core of older and mid-career employees, and the enforced accountability, was one of the keys to the Forest’s productivity during QLG. Now, that’s largely gone.
Now, a new employee coming in doesn’t feel the energy, doesn’t experience the commitment in working together as a team to get projects out, and doesn’t perceive a sense of urgency in getting projects out. During QLG, District teams would generally need two field seasons to gather the necessary data to generate a proposed action and to inform the analyses of effects within the NEPA documents. And, projects were usually staggered, where in a given winter a District team would write one or two EAs, then the following field season would represent the second and final field season for the projects for which NEPA documents would be written in the following winter, and would also represent the first of two field seasons for out-year projects. The timeframes involved in producing projects was generally all entrained, and there were sufficient non-Fire personnel to carry them through. Now, the process has become open-ended and there’s only a skeleton crew of non-Fire personnel to work on them. The problems that are currently affecting the agency and project planning are many, and many are outside of the local unit’s ability to change.
One problem is in part due to the lack of non-Fire personnel, and also due to the inexperience of some of the personnel on hand who don’t have the benefit of mentoring from experienced personnel because there’s so few of them left, and project planning is so slow that if new employees learn by doing there’s not a lot of doing to learn from. There’s a difference between being understaffed and poorly staffed, and at this point the agency is both. The lack of non-Fire staffing is greatly impacting productivity.
Another is being underpayed. Pay levels below a GS-13 are far from lucrative. When I started, it was acknowledged that government paychecks were less than similar positions in private industry, but FS employees had the non-monetary forms of compensation to make up for that – the gratification of working on public lands, being in the field, etc. Now, the pay of GS-5s thru 11s is so low that the non-monetary forms of compensation may no longer be sufficient to make up the difference between the paycheck and cost of living, especially w the recent inflation and high housing costs, especially in the tight housing markets in small, rural, scenic communities, where FS duty stations are generally located, duty stations that may also be considered desirable by retirees and others who compete for housing and drive up values. Until the agency can substantially increase pay for those levels, it will not attract or retain employees, and will not attract adequate numbers of quality candidates to apply for open positions.
High housing costs, limited housing options and low pay are also issues for seasonal employees, with some lower, entry level pay levels being below minimum wage. Seasonal employees, the employees who make up the field crews that do the surveys and collect the data critical to the NEPA process, have always been the ignored life blood of the agency. Without crews the data isn’t collected. Without the data projects do not happen.
Fire assignments are another issue. The QLG period was generally free of the large, almost annual fires that are happening now. Now, many employees on the management side abandon their management positions in order to make money on fire assignments, and may be gone on multiple assignments within a given field season. With an already depleted level of personnel on the management side, a loss of one or two critical specialists from the IDT process who abandon their management responsibilities to take fire assignments can slow the development of projects, and so projects are more and more delayed. This is especially the case during Planning Level 5s, when it becomes the priority of everyone who has fire qualifications to take fire assignments.
And then there’s also the post-fire response, starting with suppression repair or BAER assignments, but then going into post-fire management for any fires that happened on the Forest. Salvage, hazard tree removal, reforestation, etc. When IDTs are limited due to few non-Fire employees, work on post-fire landscapes delays ‘green forest’ projects yet again simply because there’s not enough teams to do both.
And, the agency has quite distanced itself from commercial timber harvest. Timber volume is now an outcome of other objectives, such as forest restoration or to enhance forest resiliency. When reading one of the agency’s recent glossy publications about the “wildfire crisis”, I did a word search and could not find the words “timber”, “commercial” or “harvest”, nor was there any discussion of the economic losses associated with the timber being killed by fire. The agency has lost its resolve to harvest timber, it seemingly does not want to be perceived as a producer of commercial timber products. Which then of course calls into question of why the lands the USFS administers remain in the USDA and are not transferred to the USDI.
An estimate was made by the Regional Office that the Dixie Fire killed about 2.3 billion board feet of timber on the Lassen. The Lassen’s recent timber volume accomplishment target that the Forest was supposed to produce was 48 million board feet. Round that up to 50 million board feet, and then realize that the Dixie was estimated to have killed the equivalent of 40 years of timber volume target attainment on the Lassen. Forty years of timber volume target dead on the landscape. The Forest was able to remove about 45 million due to some projects areas having burned that had signed NEPA, leaving about 39 years of target attainment dead on the landscape. Where it largely remains. And, without post-fire commercial salvage, the cost to pay contractors to fell, skid, deck, chip and haul the fire-killed trees in order to site prep and allow for the site to be reforested, was running $1000s/acre in recent fire areas.
The issues are many, and complex, but the agency seems to have largely lost its relevance in land management. An agency can not have relevance if it does not have resolve. The agency can’t keep trying to perpetuate the myth that it is still a ‘can do’ agency. The agency needs to acknowledge failure and then take meaningful steps to address the issues that have caused the failure. As long as those in leadership continue to profess optimism about the agency or who still work to perpetuate the myth, it will continue to decline. It is much easier for USFS leadership to point a finger of blame at something external to the agency, like the NEPA process, than to point that same finger at itself.
One fundamental change I can think of that would help the current situation is for the agency to abandon its annual timber volume accomplishment targets and instead focus primarily on accomplishing prescribed fire. The silviculture-first approach to management, with prescribed fire as a followup or secondary treatment, that has always been the agency’s approach, is obviously not working. And by continuing regarding prescribed fire only as a followup or secondary treatment the agency may never truly address and resolve the issues that prevent greater use of prescribed fire.
A prescribed fire-first approach should also serve to get fire on the ground sooner. To illustrate, take an example time-line for a typical NEPA process to unfold:
Spring/summer of Year 1: initiate field data collection within a project area.
Spring/summer of Year 2: conduct remaining field collection needs (assuming this can be completed in two years)
Fall/winter of Year 2/3: Prepare NEPA documents.
Spring, Year 3: sign the NEPA document to authorize treatments, say a timber sale w followup Rx fire.
Summer/fall Year 3: Layout, mark and advertise the timber sale.
Winter Year 3/4: Award sale.
Years 4-8: Implement sale contract. Most contracts have had a 5-year window for completion. So, if prescribed fire is to be done post-harvest, then it will have to wait until harvest is complete, which may be in five years.
Spring/fall Year 9: if a window is obtained, conduct the post-harvest burn.
So, it can take 9 years to get fire on the ground with a silv-first approach using prescribed fire as a followup treatment, assuming only two years for data collection to inform the NEPA documents. So, if a Forest started a project’s first field season in 2024, with a silv-first approach fire may not be applied to the ground until 2032. If there was a prescribed fire-first approach, and the Forest primarily used prescribed fire to create key fuel reduction areas, with no or limited pre-treatment, then fire could potentially be on the ground by the fall of year 3, and time could also be saved in the preparatory field seasons due to not needing stand exams or other silvicultural (tree counting) data gathering.