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October 10, 2007

SOURCED! - NEPA Next in Line

Following recent trends in the rest of the US Government, the Forest Service continues with wave after wave of outsourcing (or in-house "clustering") accompanied by downsizing. Feeling frustrated and helpless to right what I think wrong, I refer to those affected as having been SOURCED! or CLUSTERED! Hence the title for this post.

Back in 1995 I remember Luna Leopold telling Forest Service managers that they were presiding over the destruction of America's public forests. Today it seems that Forest Service managers are presiding over the destruction of the Forest Service itself. Maybe I'm an incurable cynic — maybe? — but it seems like we are in a crises breeder-reactor. As crises deepen, increasingly no one wants to talk about it.

The Forest Service's recently accelerated downsizing began with Information Technology and Contracting, then spread to Personnel (which now carries the title "Human Capital" following a brief moment when employees were equally demeaned by the label "Human Resources"). Right now the downsizing wave is threatening a domain that the Forest Service calls NEPA: the process for compliance with the National Environmental Policy Act of 1969. Never mind that NEPA can't quite be envisioned to be a staff function. Never mind that the responsibilities and requirements of the NEPA Act seem to many to be nothing if not "inherently governmental" — therefore not something to be SOURCED!

It gets worse: One way the Forest Service circumvents Competitive Sourcing mandates, that stem from OMB circular A-76, is by re-labeling the "sourcing" outside A-76 as "Business Process Re-engineering". The results are too often similar, resulting in clustered service centers and fewer employees.

In the "Age of Information", with emergent mass-communication networks, no one disagrees that in there ought to be some shifting from clerical worker' help to self-help. Still, bureaucratic managers seem too focused on "clustered service centers" and not enough focused on the real needs of real people both now and in the future. No one seems willing to talk through, "what work?" and "What is work?" for the 21st century. No one seems willing to talk through "Who needs to do whatever it is that is 'work'?"

The NEPA study, formally the "Feasibility Study of Activities Related to … NEPA Compliance Final Report", August 10, 2007 seems to miss the mark on every front. It is the stuff of questionnaires anchored in the air, "data calls" that mask the emptiness of the inquiry, then volumes of data fed back to NEPA practitioners as if to mask the emptiness. Someday soon, maybe we'll be able to daylight the study. Until then, I'll leave my damning 'take' of the study as one opinion—an opinion that seems to be shared by many who are voicing similar concerns internally.

A few specific problems with the "Feasibility Study":

  • Failure to recognize the relationship between NEPA compliance and administrative decision making under the Administrative Procedures Act (APA) Wikipedia: APA
  • Failure to demonstrate that NEPA compliance practices and responsibilities are not "inherently governmental"
  • Failure to fully evaluate both sides of the "contract it out" v. "working-it-inside" puzzle, thereby biasing results in favor of "contract it out":
    • Failure to fully evaluate time spent administering contracts in complex, nuanced, and ever-changing decision and analysis contexts
    • Failure to fully evaluate the costs of "farming out" responsibilities and tasks that are inherently tied to "public trust" issues that requires relationships to be built and maintained.
A few references related to A-76 and/or the NEPA "Feasibility Study":
  • Internal Organization and External Contracting for the NEPA Process: Lessons from the New Institutional Economics and Strategic Organizational Design [PDF], Kenneth Richards et al., September 20, 2007
  • Testimony on "Defining 'Inherently governmental' work, and problems arising from agencies being forced to try to 'blend' contractor and federal workforces", [PDF], Jacqueline Simon, American Federation of Gov. Employees AFL-CIO, December 19, 2005
When, if ever, will the Forest Service begin serious inquiry into how it ought to function in the 21st Century? It certainly hasn't done so to this point, and if the recent foray into "Transformation" is any guide, the agency is not about to engage in serious organizational inquiry any time soon.

{Updated: 10/11/07}

Posted by Dave on October 10, 2007 at 10:22 AM | Permalink


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Posted by: Mike Dechter

Good post.. I wanted to add a link to a recent publication entitled, "Reflections from USDA Forest Service employees on institutional constraints to engaging and serving their local communities"


The publication focuses on Forest Service employees' perspective on how departmentalization and lack of funding (and some other things) are preventing us from engaging local communities.

Mike Dechter | Oct 19, 2007 11:24:16 AM

Posted by: Wolfy

Wow, where to begin? The entire outsourcing, downsizing, clustering, or “whatever you want to call it” process has really shaken the forest service to its roots. Whatever the end goal may be, the “process” is having a rippling effect through the service and the nation. There are no anchors or cornerstones to cling to in the agency anymore. We are truly adrift in a sea of change. Our “leadership” is just along for the ride. They will just follow orders and keep their mouths shut. And moral is in the toilet. Everyone is afraid to talk about it. Apathy abounds and nobody up top cares.

Right or wrong, the forest service has had a long, distinguished record of accomplishment of getting the job done. Unfortunately, we haven’t adapted over time to be able to address changing issues. And quite frankly, we have addictions. We are addicted to cheap timber, cheap range fees, fire fighting, and NEPA. Like a junky suddenly thrown into detox, we are struggling to get our next fix, not cure our addictions. About 30% (about 8000 employees) of the service does NEPA as a part of their job. About 1200 employees do NEPA 50% of their time or more. This equates to about 3500 full time positions. The service is looking to cut 25% of these jobs and “cluster” the remaining jobs in six regional service centers. I fear that the public participation required by NEPA will be strained even more.

NEPA is just one more major activity being done by the forest service that the government is looking to downsize, cluster, or privatize. If the trends follow the historical trends established by the clustering of human resources, business management, and IT, the result will be dramatically fewer employees with more work and less connection with the public. I believe that the side effects like poor moral, confusion, frustration, and poor public service will continue to get worse.

Wolfy | Oct 20, 2007 7:15:40 AM

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