SOURCED! - NEPA Next in Line Dave

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}