November 24, 2006
US Forest Service Betterment: What would you recommend?
Suppose there was a Board of Directors for the US Forest Service instead of oversight and administration by the US Congress and the Administration. Suppose further that you were on the board. What would you recommend that the Forest Service do differently, do better, keep on doing just as it is?
I sit on a nonprofit board. The role of that or any other board is to steer within the broad organizational charter. So we are not talking here about micro-management, but rather about broad steering maneuvers. What might we recommend?
I am soliciting input here. So please chime in, and we will work up a list together. To get things rolling, here are a couple of ideas:
- Revisit and redirect agency administrative decision-making — For too long Forest Service managers have focused too narrowly on what I'll call rational planning decision frames. The agency can do much better. We need to investigate how administrative decision-making fits into the regulatory frame of governance. We need to investigate similarities and differences between how private organizations operate, managerially, and how government organizations operate. We need to better understand how the best in both worlds operate, and learn more about stumbling blocks in the path from the "is" to the "ought."
- Stop the micro-management "puppeteering" — The last two Administrations have been masterful, albeit destructive, in reaching deep into the periphery of the Forest Service to work on field level managers to do "whatever" is of daily import to political appointees. Maybe this is fine, but I don't think so. And we all know too well that Congressional types call frequently to work on USFS managers. This too seems counter to proper political administration of the agency.
On the "disease" front, here (in part) is what I argued back in 1992:
…It is no secret that American management methods are under attack on all sides. So-called Japanese methods for Total Quality Management are an emergent standard. I say so-called because the methods are very much American, as taught to the Japanese by W. Edwards Deming and others. Oddly enough, Deming got his start in the U.S. Department of Agriculture. …
Deming captured critical organizational behavior standards in his "fourteen points," which he believes are needed to move organizational behavior toward quality. They are:
- Create constancy of purpose for improvement of product and service. Purpose is at the heart of organizations. Organizations without a sense of purpose wander aimlessly, wasting away while wasting resources. Some argue that restoring and maintaining healthy and sustainable forest ecosystems should become the primary purpose for the Forest Service. In this sense the Forest Service might visualize itself primarily as a 'forest health maintenance organization,' rather than as a product and service vendor that also cares for the land.
- Adopt the new philosophy. Americans are too tolerant of poor workmanship and sullen service. Deming believes that we need a new religion in which mistakes and negativism are unacceptable.
- Cease dependence on mass inspection. One of Deming's key points is that quality is not an outcome of quality control inspections. Rather, quality comes from basic improvement in organizational processes, where workers are enlisted and gain ownership in the process.
- End the practice of awarding business on price tag alone. This means, of course, that government procurement processes have to be revamped too.
- Improve constantly and forever the system of production and service. Improvement is not a one-time effort. This means that government managers are going to have to break their addiction to 'quick fixes' and high profile 'showcasing.'
- Institute training. The Forest Service has some very good training sessions, along with some bad ones. But a unifying whole needs to be developed to relate the various parts, and to discriminate between the "good" and the "bad."
- Institute Leadership. The job of the supervisor is not to tell people what to do or to punish them, but to lead. Here the Forest Service needs to beef-up training and other 'culturing' of managers. …
- Drive out fear. Even though it may come as a shock to many Forest Service supervisors and managers--as it comes as a shock to many under Deming's method in the private sector--fear is real, and pervasive throughout the Forest Service.
- Break down barriers between staff areas. It is no secret that the Forest Service is functional and increasingly so as one goes up the ranks. …
- Eliminate slogans, exhortations, and targets for the workforce. …Deming's message here is that management by slogan is not management, just rhetoric.
- Eliminate numerical quotas. Quotas take account only of numbers, not quality or methods. They are usually a guarantee of inefficiency and high cost. It is time to recognize that government employees are not indolent and unmotivated, but good people facing nearly insurmountable obstacles. That anything useful gets done at all is a credit to those government employees who do creative and useful work in spite of the system.
- Remove barriers to pride of workmanship.
- Institute a vigorous program of education and retraining.
- Take action to accomplish the transformation. It will take a top management team with a plan of action to jump-start the quality revolution. Thereafter, top management must commit themselves completely to the task of overseeing the revolution. Workers can't do it on their own, nor can managers. A critical mass of people in the company must understand the Fourteen Points as well as the Seven Deadly Diseases. [For more, see: The Deming Management Method, Mary Walton, 1986 or The New Economics: For Industry, Government, Education, W. Edwards Deming, 1994]
Adherence to Deming's "fourteen Points" can only begin in earnest when employees and managers are familiar with what Deming calls the "seven deadly diseases." Deming believes that these diseases, if not corrected, can be fatal to organizational health.
As we look at the seven deadly diseases and then relate them to the Forest Service, we must remember that problems identified are not unique to the Forest Service--they likely extend to all government agencies. Much like the current movement to make corporate America competitive, we need to rethink the institutional underpinnings of government, especially in terms of principles and practices for administration. Deming's seven diseases and fourteen points provide a place to start.
Deming's "seven deadly diseases" [from The Deming Management Method, p. 36]:
I will not dwell on six and seven, but mention them for completeness and as a reminder of other tasks on the table for Congressional attention relative to the private sector.
- Lack of constancy of purpose. "A company that is without constancy of purpose has no long-range plans for staying in business. Management is insecure and so are employees."
- Emphasis on short-term profits. "Looking to increase the quarterly dividend undermines quality and productivity.
- Evaluation by performance, merit rating, or annual review of performance. "The effects of these are devastating--teamwork is destroyed, rivalry is nurtured. Performance ratings build fear and leave people bitter, despondent, and beaten. They also encourage mobility of management."
- Mobility of Management. "Job-hopping managers never understand the companies that they work for and are never there long enough to follow through on long-term changes that are necessary for quality and productivity."
- Running a company on visible figures alone. "The most important figures are unknown and unknowable--the multiplier effect of a happy customer, for example."…
- Excessive medical costs.…
- Excessive costs of warranty, fueled by lawyers that work on contingency fee.
Deming's first disease, lack of constancy of purpose, is a big problem in the Forest Service. There is widespread disagreement as to the agency mission when one gets deeper than the slogan "Caring for the Land and Serving People." Forest Service leaders [were] well aware of this condition [in 1992, but may have forgotten since].
The Congress has given the Forest Service ample guidance regarding purpose. Too much, some argue, and way too inconsistent when looking at the long term goals outlined by the Congress and the pattern of appropriations from year to year. V. Alaric Sample, in his book The Impact of the Federal Budget Process on National Forest Planning, 1990, has done a good job of chronicling both the problem and the process. It is … up to the Congress and the Administration to figure out how to fix what is broken.
The Congress and the Administration can't accept all the blame for the mess the Forest Service finds itself in, though, regarding 'lack of constancy of purpose.' The forestry and engineering professions (and the large number of top Forest Service officials from those professions) have much to do with the problems between the so called old-guard and the young-turk professionals that have very different worldviews. Both forestry and engineering have denied ecology, and forestry has denied systems theory until very recently.
One thing is clear: Lack of constancy of purpose is a widespread disease in the Forest Service. Ecosystem Management is one step in a right direction, as was the change of the 1990 RPA toward strategic policy development and away from production planning, but more steps are needed to effect the cure.
Deming's second deadly disease is emphasis on short-term profits. The Forest Service can hardly be said to have this disease…. But in truth the disease is widespread. It is just a different strain of the virus. For the Forest Service, and most other government agencies, the mutant virus is emphasis on short-term targets. The disease is every bit as deadly as its cousin.
Deming's third deadly disease is evaluation by performance, merit rating, or annual review of performance. [Why this is still the 'standard' is one of the wonders of American government organizational life.]
Deming's fourth disease is mobility of management. The Forest Service is constantly grooming 'line officers' for changes in assignment. And the agency has a long standing policy for moving folks around generally. The Forest Service family--patriarchal as it has been, with the Chief at the top—maintains the 'intense loyalty' for which it is noted, in part, through this mobility policy.
Deming's fifth disease is running the company on visible figures alone. This disease is associated closely with an earlier one but merits attention because the Forest Land and Resource Management Plans, the Program Development and Budgeting process that is used to develop budget proposals, the Congressional Budgeting Process, and many other processes are evidence that the Forest Service is trying to run the organization predominantly by the numbers. …
Defeating the Diseases So how does the Forest Service begin to defeat the diseases? As I mentioned, the effort will take a joint effort from the Congress, the Administration, and the agency. But the Forest Service can take the lead. … If the Forest Service fails to implement needed behavior changes, then those small pockets of "health" [that emerge from time to time, under constant attack from organizational immune system responses] will likely wither and die as, eventually, so will the agency. …
[2006 endnote: Perhaps the agency's new found interest in "principle centered management/leadership" will jump start a betterment process. Let's hope so. But let's not stop throwing in our "two cents worth" either.]
November 15, 2006
How to Avoid Harebrained, Cockamamie Schemes
During frequent lunchtime conversations, a friend often uses the term "cockamamie" to refer to the latest in Forest Service activity traps and decision traps. This morning I added "harebrained" to the title just for spice. Together, the two words capture the absurd nature of getting caught in the traps, which unfortunately seems to be the norm in the Forest Service these days.
Activity traps are simply those where we get so caught up in the day to day activities of an organization that we forget to take time to attend to the main purposes and objectives of the organization. Decision Traps are simply those were we get so caught up in the momentum of decisions (and the crises that often force them) that we forget common sense in the decision process and/or forget to pay attention to betterment of the decision process.
Activity traps are everywhere in the Forest Service and other organizations. I don't have a handy-dandy list, but would append one here if anyone else does. Attend almost any meeting or conference call, and you can begin to develop such a list. Not too long ago, I overheard a conversation between a policy professor and a Forest Service planner about the planners' schedule which was 'booked solid' for the next month. The professor finally said, "I don't get it. You Forest Service people are always in meetings—meeting with yourselves. How do you ever get any work done?"
Decision Traps have likely had more formal attention in the literature. J. Edward Russo and Paul J.H. Schoemaker's Decision Traps: The Ten Barriers to Brilliant Decision-Making and How to Overcome Them is a good place to begin. Here is their list of 10, and a few questions I threw together that might help folks avoid the trap:
- Plunging In: Gathering information before spending time to reach agreement about why the information is important or how it will help. When was the last time you found yourself engaged in a process that seemed mired in this trap? How is it that we spend so little time to reach at least some agreement on informaiton needs, recognizing that we can never know all that will be required and knowing too the tradeoff between informaiton gathering traps and the plunging in trap.
- Frame Blindness: Setting out to solve the wrong problem due to a lack of perspective. If you didn't work for "the government," would you be more likely to ask hard questions about frames? Why ? Why not ask them now?
- Lack of Frame Control: Defining the problem from only one perspective (i.e. too few frames) or continuously redefining the problem (too many). Are there any signs that current thinking is either too structured or too unstructured?
- Overconfidence in Your Judgment: Failing to gather key information because of overconfidence about assumptions or opinions. Are there concerns being raised about process that may not have been adequately aired or discussed? Or worse, are concerns not even being raised?
- Shortsighted Shortcuts: Overly relying on convenient facts, "rules of thumb", or "traditional approaches" without questioning whether they fit the situation. If a hypothetical outside decision-maker were presented with the information currently being gathered, where might he or she feel uncomfortable about making the needed decision? Can any given decision pass the "red face" test"? (Note: the point is not to gather all information possible and paralyze the process, the point is to not leave gaping holes).
- Shooting From the Hip: Failing to rely on a systematic process to keep all valid information available when making a decision. Is there any information you're getting that might prove pretty useless or that might be mistakenly discarded? What organization processes help us avoid this trap while not leading us into other traps?
- Group Failure: Assuming that smart decisions and good work emerge from groups of smart people without any management of group process. What is it about government group process that tends to force decisions and work toward dumbness rather than smartness?
- Fooling Yourself About Feedback: Failing to interpret outcomes of past decisions for what they really say. Is a process generating enough but not too much feedback to correctly understanding what's coming in now?
- Not Keeping Track: Assuming experience is obvious and there is no need to track results or look for less obvious lessons. Is there a clear, workable strategy for tracking and 'reflecting on' decision process, decision content, and decision outcomes? Is there a related process for tracking 'lessons learned' so they become shared knowledge?
- Failure to Audit Your Own Decision Process: Paying attention to only the pieces and not their interactions and how they affect each other. When was the last time you reflected on, or inquired about your decision process? When was the last time you saw anyone reflecting on decisions or decision process?
November 03, 2006
A Simpler Way…
If politics (internal and external) weren't corrosive and corrupt, if legal precedents were easier to undo, if top brass in the Forest Service were more amenable to "learning organization" management approaches, I'd recommend that the Forest Service revise the "planning rule" to read, simply and exclusivlely:
2007 NFMA Planning Rule: Once every 10 to 15 years revise the forest plan.Why? First, NFMA requires a planning rule so, barring repeal of RPA/NFMA I guess we need 'a rule.' Second, each and every 'rule' since 1979 has proved to be a disaster in part, or in the main because of an in-built tendency for the Forest Service bureaucracy to over-complicate everything it touches. Third, management theory and practice has moved far away from the 'comprehensive, rational planning' ideas of the past. Instead management theory and practice has moved toward "Sensemaking" following ideas from Karl Weick and others that separate the world into realm of "expected" and "unexpected." Forest planning, arguably is deep into the realm of "unexpected" (wicked problems, surprise, novelty, etc.) and ought to be treated as such.
At the same time we need to decommission the Manual and Handbook system. (one of my long-standing policy recommendations ).
Certainly the agency would have an interesting journey working up an EIS to accompany a shorter non-rule "rule." It would prove interesting to see how the Forest Service might begin to frame Sensemaking, Scenario Planning, Adaptive Management, and organizational learning as part of a new Simpler Way to management. Framed here in an EMS context.
But hey, what ever happened to the Forest Service sense of adventure? Certainly the agency must have had a sense of adventure, sometime in the past. Or are all the tales told of earlier eras just tall tales?
So what the hell, I recommend that the Forest Service take this step in spite of the political and legal environment. Agency policy-makers keep shooting themselves and agency practitioners in the foot by over-complicating things. Time to try something different.
Note: Just so you know, I am a big fan of Margaret Wheatley and Myron Kellnor-Rogers approach that we can label A Simpler Way following the title of their renowned book. Here's a link to some of Margaret Wheatley's work.
Note Further: Links to related Iverson rants:
November 02, 2006
Forest Service '2005 Planning Rule' Now in Court
Amid much hand wringing in the Forest Service over the expected-last-summer but not yet delivered from CEQ "categorical exclusion" from EISs for forest plans, AND much hand wringing over the expense and process-gridlocking nature of EMS as evidenced on pilot forests, the agency now has one more thing to wring hands over. A coalition of 19 environmental groups and the state of California just took the 2005 planning rule to court:
[10/31/06 Dan Berman, Greenwire senior reporter reports [$]] A coalition of 19 environmental groups and the state of California will head into a San Francisco court tomorrow to attempt to convince a federal judge to void the Bush administration's revision of a planning rule that governs all 192 million acres of national forests.
Judge Phyllis Hamilton of the U.S. District Court for the Northern District of California will hear arguments in two separate lawsuits challenging the National Forest Management Act planning rule implemented in January 2005 that environmentalists say allow forest managers to cut corners on natural resource protection. The Justice Department, supported by the timber industry, is asking Hamilton to dismiss the lawsuits.
…The plaintiffs charge the Forest Service failed to adequately consider the environmental effects of the rule change under the National Environmental Policy Act and failed to consult with other agencies -- the Fish and Wildlife Service and National Marine Fisheries Service in particular -- on what the rules would mean for wildlife in national forests.
The rule removed a requirement to manage forests to ensure "viable populations" of at-risk species in national forests in forest plans and required managers to develop plans more broadly and put social and economic considerations on par with ecological sustainability. …
In addition to challenging the letter of the planning rule, the environmentalists charge the administration violated NEPA by skipping an environmental impact statement or environmental assessment for the planning rule. Instead, the Forest Service used a "categorical exclusion," ….
In a recent brief, the Justice Department argued the planning rule itself has no environmental impact because it mandates no on-the-ground action, making an EIS or EA of the rule impossible.
"The 2005 rule is a procedural rather than prescriptive rule and is so far-removed from future ground-disturbing activities that any attempt to analyze its environmental effects would be a meaningless exercise in speculation," the DOJ argued. "The rule itself does not change the physical environment in any way; it is not intended to, and will not, determine the mix of multiple uses that will ultimately be selected. Hence, the rule does not indirectly cause a known set of environmental impacts that could be analyzed."
The environmentalists also charge the Forest Service violated the Administrative Procedures Act when it added Environmental Management System (EMS) protocols in the final version that never appeared in the draft.
"The final is so different from the draft that the public didn't have an opportunity to comment," [Mike Leahy, Defenders of Wildlife attorney] said. EMS "came out of the blue," he added. "In the final it's the most central part of forest planning. Nobody could have possibly foreseen that coming." …
[11/02/06 The Land Letter editor Arthur O'Donnell (w/ senior reporter Dan Berman) reports] SAN FRANCISCO -- Judge Phyllis Hamilton told parties she is not ready to rule on summary motions filed in two consolidated cases challenging the Bush administration's revisions to a planning rule adopted last year that would affect all 192 million acres of national forest.
During oral arguments held yesterday in the U.S. District Court for Northern California, attorneys for Defenders of Wildlife, Citizens for Better Forestry (CBF) and the California Office of the Attorney General argued that the 2005 rule should be voided because the Forest Service failed to follow provisions of the National Environmental Protection Act, the Endangered Species Act and the Administrative Procedure Act. In particular, they challenged the agency's declaration of a "categorical exclusion" from public notice, comment and consultation provisions embodied in these laws [Defenders of Wildlife et al. v. American Forest and Paper Association, C04-4512PJH; and Citizens for Better Forestry v. U.S. Department of Agriculture et al., 05-01144PHJ].
In response, the Department of Justice argued that the action of formulating the rule change was so far removed from any actual impacts on lands or species that the agency would not be able to conduct any meaningful environmental analysis. The Forest Service is not avoiding the law, said DOJ senior attorney Cynthia Huber. Instead it is reserving such analysis and activities until the more appropriate time, when a specific forest plan or program is being considered.
Both sides agreed that the revisions to the rule represent a "paradigm shift" in how the Forest Service directs local forest units to devise forest management plans. But what the government described as "changing to a more flexible and less prescriptive framework," the plaintiffs criticized as "moving from a protective standard to a weaker one."
What the plaintiffs want, said California Deputy Attorney General Raissa Lerner, is for the court to set aside the 2005 rule and reinstate the 1982 regulation. …
The environmentalists' attack on the rule was laid out in three parts. Attorney Pete Frost, representing CBF, said that the Forest Service failed to provide any kind of NEPA environmental assessment of the impacts its rule change would have on protected species and lands. While a full-blown environmental impact statement should be required under NEPA, he said, at the very least there should have been an environmental assessment involving three elements of NEPA: the [species] viability requirement; a description of the affected environment; and a reasonable range of alternative. "That's entirely missing in this," Frost said.
Use of the categorical exclusion is inappropriate, Frost said. "The categorical exclusion doesn't fit. Even if it does, the rule has indirect effects that require the agency to prepare a NEPA analysis."
Frost similarly argued that the Forest Service ignored provisions of the ESA that require the agency to consult with other federal agencies, such as the Fish and Wildlife Service, on potential effects of the rule change. While the government again asserted a categorical exclusion, Frost said that the extent of impacts the new rules will have "stretched CE past the breaking point." …
Representing Defenders of Wildlife, Earthjustice attorney Trent Orr further argued that the agency violated APA by not giving the public sufficient ability to comment on significant changes it was proposing. "In the final rule, the Forest Service deleted a variety of very specific protective standards that had been in the [prior] rules," he said. In addition, the rule declared that forest units should employ an adaptive management technique called "environmental management system" of which Orr said, "there was absolutely no mention of in the proposed rule."
The agency also applied an administrative corrections provision, that is meant to correct nonconsequential errors, maps and data without having to undergo a lengthy public review process. Instead, Orr said, the rule would apply it to such key determinations as timber harvest estimates or species monitoring programs that are "subject to intense public interest."
Together these amount to significant changes in the way the Forest Service manages its lands, Orr said. "I don't see how announcing a paradigm shift in the final rule can be considered by any stretch of the imagination as giving the public the chance to comment on it." …
In defense, DOJ attorney Huber held to a consistent line of argument that the "2005 rule is so far removed from having on-the-ground or ground disturbing effects, there is no meaningful way to analyze what impacts there might be."
Huber also said that use of the categorical exclusion was "entirely appropriate" in cases of amending and revising existing plans, when the agency has reviewed its history of actions and determined the planning rules will not have a significant environmental impact. "Use of the CE is not getting out of NEPA. It is the right NEPA process for this action," she said. "These are service-wide rules, processes and instructions that deal with all 192 million acres of land. The simple fact that there are threatened and endangered species on some Forest Service lands does not mean there are significant environmental effects on those species."
Huber concluded, "The agency is not suggesting that analysis will never be appropriate, but the timing is not right."
In her comments prior to the oral arguments and in her line of questioning, Judge Hamilton seemed amenable to an argument against conducting a full environmental impact statement for the rule revision but said she did not understand the position that agency consultations were not necessary. "The defense raised an issue I find most troublesome," she said. "How does the Forest Service really analyze environmental impacts of changing its processes? This is not a discrete issue, but indeed the entirety of how it conducts these reviews."
On the other hand, with regard to the ESA, Hamilton observed, "The law requires a duty of consultation almost always on some level. Frankly, I don't understand the government's position on why no consultation was necessary." She also questioned the lack of public comment ability on the final rule's "paradigm shift."
On the question of remedies, should the government be found in violation on any of the counts, the judge seemed to contemplate issuing an injunction against the 2005 rule while remanding the issue back to the agency.
"We believe remand is an appropriate remedy," said DOJ attorney Huber. "But we don't believe an injunction is appropriate without further briefing ... until we have a better idea of the nature and extent of the violations are."
In the end, though, the judge told the parties she was not prepared to rule on their summary motions and that they should not expect a decision "really soon."