United States

Department of

Agriculture

Forest Service

Pacific Northwest

Research Station

General Technical

Report

PNW-GTR-766

November 2008

Factors Influencing Line Officers’

Decisions About National Environmental

Policy Act Project Design and Development

Donald G. MacGregor and David N. Seesholtz
The Forest Service of the U.S. Department of Agriculture is dedicated to the

principle of multiple use management of the Nation’s forest resources for sustained yields of wood, water, forage, wildlife, and recreation. Through forestry

research, cooperation with the States and private forest owners, and management of the national forests and national grasslands, it strives—as directed by

Congress—to provide increasingly greater service to a growing Nation.

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employer.

Authors

Donald G. MacGregor is a consultant, MacGregor-Bates, 1010 Villard Ave.,

Cottage Grove, OR 97424. David N. Seesholtz is a research liaison, U.S. Department of Agriculture, Forest Service, Pacific Northwest Research Station, Forestry

Sciences Laboratory, 620 SW Main St., Suite 400, Portland, OR 97205.

Cover Photo

Rolando Mendez, Deputy District Ranger on the Bend - Ft. Rock Ranger District,

Deschutes National Forest
Abstract

MacGregor, Donald G.; Seesholtz, David N. 2008. Factors influencing line

officers’ decisions about National Environmental Policy Act project design and

development. Gen. Tech. Rep. PNW-GTR-766. Portland, OR: U.S. Department

of Agriculture, Forest Service, Pacific Northwest Research Station. 27 p.

Prior to the existence of the National Environmental Policy Act (NEPA), Forest

Service district rangers had considerable latitude to make resource management

decisions and execute management plans with relatively little encumbrance by documentation and process requirements. Today there appears to be differences not

only in the district ranger population, but in the decisionmaking processes they use

and how they adapt their management style to particular circumstances. Indepth

interviews were conducted with 12 district rangers to obtain their experiences with

project design and development, and how project planning is influenced by considerations about the NEPA process. District rangers appear to have changed their

management style to accommodate a shifting social and policy climate, and rangers

often view NEPA as a risk factor and as a process to be managed. Research methods

can be used to further analyze risk in terms of resource versus process risk, both of

which can potentially affect the agency in terms of opportunity and monetary costs,

efficiencies, and decision confidences.

Keywords: National Environmental Policy Act (NEPA), planning, land management decisionmaking, Forest Service.
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Factors Influencing Line Officers’ Decisions About National Environmental Policy Act Project Design and Development

Introduction

Over the past four-plus decades, several studies have characterized the forest ranger

position, starting with Kaufman’s now-classic The Forest Ranger (1960). Using a

set of five district rangers, Kaufman developed a profile of Forest Service rangers

based on indepth interviews. His characterization of rangers as operating within a

hierarchical structure to implement and execute agency policy objectives through

decisionmaking at the local level portrays rangers as field executives primarily

concerned with economy and efficiency. Thirty years later, Tipple and Wellman

(1991) reviewed Kaufman’s ranger profile and, based in part on Tipple’s agency

experience, noted that the emphasis on economy and efficiency had shifted toward

representativeness (e.g., workforce issues) and responsiveness (e.g., public involvement vis-a-vis National Environmental Policy Act [NEPA] requirements). Subsequent studies using survey-type methodologies to characterize the line officer

population, including district rangers, have identified shifts in ranger values over

the period from approximately 1989 to 2004. Although line officers’ perceptions

of agency resource-use values changed sharply over that period, particularly for

timber and water, line officers’ personal judgments of resource-use values changed

relatively little (Kennedy et al. 1992, 2005).

Research to date suggests that district rangers change their management style

over time to accommodate a shifting social and policy climate, and that rangers

are sensitive to the changing resource-use priorities within the agency. However,

deeper questions about how district rangers adapt their unique management style

to particular management circumstances have yet to be addressed. Although ranger

perceptions appear sensitive to agency resource values, it is unclear how these perceptions along with other local management goals and objectives, as well as rangers’ individual values, interact to determine the projects and activities that rangers

choose (and choose not) to undertake.

The USDA Forest Service ranger districts are a focal point for the design and

development of resource management projects to achieve the multiuse mission of

the agency. Many of these projects involve the assessment and disclosure of environmental impacts under the requirements of NEPA. Since its inception in 1970,

NEPA has called upon agency management and staff to undertake detailed analyses

of their proposed management actions, the anticipated impacts of those actions, and

(under some circumstances) the steps planned to mitigate unwanted or undesirable

effects, and to submit their plans and analyses to public disclosure. The NEPA
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GENERAL TECHNICAL REPORT PNW-GTR-766

process is intended to help public officials make decisions that are based on understanding of environmental consequences, and take actions that protect, restore, and

enhance the environment (NEPA 2003). Many projects succeed in the NEPA

process; when they do, the investment in planning and analysis yields a return in

terms of benefits to the natural resource base. Other projects succeed in NEPA but

only after protracted appeals and litigation in which project opponents can stall or

stop a proposed project through court or administrative actions. In these cases, the

investment in planning and analysis may be relatively high, and unless the project

return is commensurably high, the net value of the project may be dubious and the

investment may offer little return. Finally, some projects fail in the NEPA process,

in which case the investment is lost and the desired benefit to the resource base is

foregone.

Although the original intent of NEPA was to ensure that projects planned by

federal entities disclose environmental impacts of their actions and effects, legislation has resulted in planned projects being submitted to a potentially contentious

process, the outcome of which may be uncertain at the time the project is conceptualized. At present, we have little understanding of how NEPA as an environmental

disclosure process interacts with other processes inside ranger districts that relate to

the design, development, and implementation of projects as part of units’ natural

resource management objectives. Is NEPA being used purely as an environmental

disclosure process, or is it being used as a decisionmaking process for project

design and development?

To address this question, an exploratory study was undertaken to better understand how resource management projects in ranger districts evolve from an initial

idea or concept to project development and through the NEPA process. Twelve

district rangers were interviewed concerning their experiences with project design

and development, and how project planning is influenced by considerations about

the NEPA process. Some of their direct quotes appear in the margins throughout

this paper.

At present, there are 523 ranger districts in the National Forest System

(Thompson 2007). A small handful of district rangers cannot be expected to

provide a comprehensive and reliable picture of the relationship between project

development and the NEPA process. The purpose of this study was to identify

problem-framing concepts and hypotheses that provide useful guidance and direction for addressing the larger research question posed above.

Many projects

succeed in the NEPA

process; when they

do, the investment

in planning and

analysis yields a

return in terms of

benefits to the

natural resource

base.
3

Factors Influencing Line Officers’ Decisions About National Environmental Policy Act Project Design and Development

Study Approach

Ranger Identification and Selection

The rangers were selected from a database developed by identifying key informants

who in the judgment of experienced district rangers and other line officers would

provide useful information for the project. The initial database contained rangers

from the nine geographic regions of the USDA Forest Service. Individuals were

contacted by telephone and e-mail to solicit their support and involvement. The

final selection of 12 individuals was based on several factors, including their geographic location, availability to be interviewed, and interest in the project. As much

as possible, rangers were selected to provide regional diversity. Owing to time and

availability constraints, it was difficult to include rangers from units in Southern

and Eastern regions (e.g., Regions 8 and 9) and Alaska (Region 10). The final set

of interviewees came from ranger districts in Western, Southwestern, Intermountain, Pacific Southwest, and Pacific Northwest (Regions 1, 3, 4, 5, and 6).

Interview Process

Rangers were interviewed to elicit their backgrounds and experiences. Interviews

were conducted at convenient locations, including unit offices, forest offices, or the

interviewee’s residence. Interviewees were given the opportunity to choose the

location and to select a timeframe convenient to them. Interviews were scheduled to

take approximately 1 to 1 1/2 hours.

An interview guide was prepared to provide a structure for the interviews and

to lend continuity to the interview process. The guide was developed around four

orienting themes:

• How projects are initially identified and selected.

• How a selected project concept is developed prior to any NEPA-related

analyses.

• How projects are influenced by various aspects of NEPA.

• When during the process the management decision is made and the role of

the environmental analysis.

Additional background information was collected as part of the interview

process, including characteristics of the line officers and their career paths as well

as characteristics and management complexities of their units. The actual conduct

of the interview was varied to take advantage of interviewee responses and to allow

for opportunities to adapt the interviews contingent on what was learned as the
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GENERAL TECHNICAL REPORT PNW-GTR-766

interviews progressed. Interview content was analyzed to identify themes, concepts,

and information of value for framing further study.

Findings

District rangers and the management context: sources of variance—

Significant differences may exist in terms of district rangers and the context of the

units they manage. Although degrees in forestry, natural resource management, and

other natural sciences have been the traditional education preparation for rangers,

there is more diversity in educational background and experience in the ranger

population today (Koontz 2007). Rangers and other agency personnel are being

asked to play a much different role than in the past as social values are at the heart

of many of the environmental issues they manage. However, most managers are

traditionally unprepared to deal with such value-laden issues and the consensusbuilding process needed in decisionmaking to successfully implement land management decisions (Magill 1991, Martin et al. 1996). Public administration, business

administration, social science, and other non-natural science degrees provide the

advanced educational preparation for some rangers. The type of educational preparation a manager receives may influence how they approach their role as a line

officer and the relative emphasis they give to various aspects of the position. For

example, those with forestry degrees will be oriented to appreciate the natural resource aspects of the position. Those with educational background in, for example,

social or administrative sciences may approach the position from a fundamental

appreciation of the social aspects of resource management. An education in business

administration may uniquely attune the line officer to the business management

aspects of the position.

How rangers enter into the line officer career path can differ considerably.

Some rangers are identified by their managers as having the characteristics and

qualities that would make them a good ranger candidate and are mentored for the

position. This tends to follow the traditional pathway in the agency, by which line

officers were identified by senior line officers and specifically mentored into the

line officer community. Although formal mentoring programs are virtually gone

from the agency today, this tradition still exists and is a means by which many line

officers achieve their initial entry.

Others desiring a ranger career take steps on their own toward achieving that

position. These steps may involve openly expressing to the line officer their interest
5

Factors Influencing Line Officers’ Decisions About National Environmental Policy Act Project Design and Development

in becoming a ranger. They may seek temporary line officer positions or deputy

positions that place them in a line officer role where they can obtain knowledge and

experience.

It is not uncommon for some rangers to be either unsure of their ranger qualifications or have no specific line officer career plans, yet become rangers after

occupying the position on a temporary assignment. Changes over the past two

decades in how the agency identifies and develops its line officers have tended to

create multiple pathways by which individuals reach the line officer position.

The experience base of rangers differs and is changing from the traditional

background in timber management and related activities. Some rangers have a

strong NEPA background, perhaps the result of one or more staff positions as, for

example, a planner or interdisciplinary (ID) team leader. Others do not and rely

heavily on unit staff members, for example, to provide detailed knowledge and

experience in the NEPA process. Rangers differ in how they perceive the district

ranger position in the context of their overall agency career objectives. Some

rangers view the position as a step on the line officer career ladder and regard their

district ranger role as entry level. These individuals may actively seek promotion

to, for example, forest-level positions and remain in one location for a relatively

short period. Other rangers view the position as a desirable career end point and

choose to remain in their current position and location, or relatively close by.

This latter group may make significant progress in developing strong community

relations as a result of their long tenure in their location. This group may also have

strong ties to direct involvement in resource management decisionmaking, and

place a high value on observing the results of their management efforts in terms

of direct action on the ground and the ultimate outcomes and changes to the natural

resources they are managing. Their tenure may also afford them the ability to develop a strong working relationship with staff and take greater advantage of staff

expertise and training in the skills relating to the NEPA process. Along these same

lines, rangers who occupy their position for longer periods may achieve a higher

level of team integration among staff members and communicate more efficiently

about the management direction (and projects) they seek to pursue, as well as forge

projects that move more quickly from concept to analysis and documentation.

The perceived qualities of what constitutes a good ranger (or ranger candidate)

differ. The ability to communicate well with both agency and stakeholders ranks

high with some. For others, liking to work with people is a primary qualification.

A strong capability, willingness, and desire to develop collaborative relationships

“I put a lot of value on

people taking their

time to get to this

position.”

“Our society is so

incredibly polarized

that no matter what

decision we make

there are going to be

those that love you

and those that hate

you and then there

are those in the

middle, and you have

to be okay with that.”
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GENERAL TECHNICAL REPORT PNW-GTR-766

with the public and other nongovernmental stakeholders is perceived to be a hallmark of good ranger qualifications. Technical knowledge or skill in dealing with

the NEPA process is seldom, if ever, seen as a quality required to be a good ranger.

The management style of district rangers differs in many ways. With regard to

staff, some rangers may have a very hands-off style in which they encourage staff

(i.e., disciplinary specialists) to freely generate and identify projects for the unit.

Open solicitation for project ideas may even extend to clerical staff and others on

the unit not directly involved in a resource area. This style of management emphasizes inclusiveness and involvement of unit personnel. Rangers having this management style may also place higher importance on a consensus style of project

development, whereby agreement among staff and line is a significant barometer

for when a project has achieved the right scope and level of detail in its environmental analysis.

Other rangers may prefer a hands-on style of management in which project

development is undertaken in the context of a more rigorous planning process that

is strongly led by the ranger. This category of rangers may have more experience

with planning processes as, for example, part of their pre-ranger assignments as a

staff specialist. How the ranger interacts with and manages staff may be related to

the strength and qualifications of their ID team leader as well as the number and

qualifications of staff on their unit. For some rangers, the level of NEPA background and expertise on their unit may be of significant concern.

Resource management contexts may differ considerably in terms of unit characteristics (e.g., staffing, budget), resource management complexity, and sociopolitical factors. Although commonalities between units exist, each unit has its

own set of management challenges, some owing to the resource base and some

owing to the social context within which the unit must operate. Project selection

and development, to be successful, takes account of both the variable needs of the

resource base as well as the social environment within which the project is to be

implemented.

The process by which a particular ranger is chosen to manage a particular

agency unit is not explicit and well defined. Rangers may tend to self-select themselves into management situations according to their own values and career goals,

the opportunities that present themselves, and the needs of the upper level managers

(e.g., forest supervisors) who select them. The idiosyncratic nature of this process

suggests that the concept of “fit” between a ranger and their resource management

context may be a useful way to understand how and why the NEPA process may

be, for example, more efficient in some districts than others.

“It’s critical that rangers be able to visualize

solutions for issues

and problems and

methods of operation.”

“The biggest (source

of) complexity we have

is staffing; it’s funding,

which relates to having

adequate numbers of

resource staff to carry

on the job.”
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Factors Influencing Line Officers’ Decisions About National Environmental Policy Act Project Design and Development

Assessing ranger districts and the potential fit with the characteristics of their

managers requires criteria or standards by which this can be gauged. Efficiency is,

potentially, one such standard. Although the efficiency of the NEPA process is

generally discussed as important to improving how the agency deals with NEPA,

systems and measures for addressing efficiency require refinement and specification

(Jesse 1998, Luther 2005, USDA Forest Service 2002). Several potential measures

of efficiency present themselves, based on the general notion that time and cost

considerations are important to make the best use of unit resources. For example,

cost to achieve the completion of a NEPA analysis might be one indicator of

efficiency. Another might be the time required to move from an initial project

concept to a completed environmental assessment (EA). Communication between

line management and staff, as well as communication between staff members constitute the basis for another set of potential measures. We conjecture that the

development of suitable measures and methods for assessing NEPA efficiency will

be most productive if focused on multidimensional indicators that take into consideration time, cost, and stylistic aspects of management. These indicators should

account for not only the economic efficiency associated with a particular NEPA

project, but also the efficiency achieved by the planning aspects of unit management that include the scoping and staging of multiple projects developed over

time. Additionally, more attention needs to be placed on evaluating the substantive

purpose and outcome of the process in evaluating or measuring efficiency

(Cashmore 2004).

Source and scope of project concepts—

Project concepts may be generated in a number of ways and come from a number

of sources. The Land Management Plan (LMP) process provides an overarching

context for project concepts, and candidate concepts must, by policy, fit within

this framework. How project concepts are identified and developed may differ with

ranger district and with individual rangers’ management style (Yaffee 1999). In

general, project concepts can be subjected to a number of influence factors that push

them to becoming either larger or smaller in scope and complexity. The following

tabulation lists some of the factors that influence project scope:

The development of

suitable measures

and methods for

assessing NEPA

efficiency will be

most productive

if focused on

multidimensional

indicators that take

into consideration

time, cost, and

stylistic aspects

of management.
8

GENERAL TECHNICAL REPORT PNW-GTR-766

Promote larger projects Promote smaller projects

Multiuse agency mission NEPA process considerations

Interdisciplinary perspective Unidimensional project objectives

Economic efficiency Issue-focused environmental

opposition

Systemic view of the ecology Disciplinary isolation of staff

Perceived need to involve staff

members Limitations on funding resources

Line officer incentive and promotion

system Healthy Forest Restoration Act

(HFRA) and Health Forest Initiative

(HFI)

Planning approaches Targets

General public support for the

agency and its mission Hot-button issues

“Targets” (both soft and hard) are one possible common source of projects.

Target-based projects may come from an upper level management unit (e.g., forest,

region) and may or may not be directly linked to the LMP. Project concepts may

come from outside the agency in the form of permits or requests to use or impact

the resource base; examples include requests for mining permits, grazing permits,

and the routing of electrical power or natural gas transmission lines.

Staff can also be an important source of project concepts, with identification

based on disciplinary considerations or observations of, for example, the presence

of risks to the resource base or the need to improve forest health. Staff-generated

initial project concepts may or may not be integrated across disciplinary specialties

when presented to the line officer for consideration, depending on several factors

including (a) how well the various disciplines working on a unit are able to communicate and develop integrated project concepts independent of line officer involvement, and (b) the experience and capabilities of the local ID team leader.

More or less work and effort may need to be undertaken by the district ranger to

shape staff-generated projects and to integrate them across disciplinary lines if

needed.

Projects may be initiated and developed by district rangers to improve or

enhance community relations. Although some of these projects may have only an

indirect relationship to the natural resource base, they are possibly perceived to

improve the relationship between public stakeholders and the agency, with the

anticipated result that natural resource projects will encounter a more receptive

sociopolitical environment during the NEPA process. Projects along these lines

and that provide what the district ranger sees as the necessary social base for

“(I’m looking for)

somebody that isn’t

narrow minded or

thinking: I’m going to

plow the deep roads

for wildlife. I’m going to

fight the good fight for

my species.”
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Factors Influencing Line Officers’ Decisions About National Environmental Policy Act Project Design and Development

resource projects may take significant time and effort that factor into the calendar

time required to develop and implement NEPA projects.

Rangers may inherit partially completed projects from their predecessors.

These projects may have partially completed environmental analyses associated

with them, and a significant investment may have already been made in moving the

project through various parts of the NEPA process. The rationale for the project

may not be clear and staff may not fully understand what the previous line officer

intended by pursuing a particular project and its alternatives. Reconstructing the

project and its logic can be time consuming. Abandoning the project altogether can

be problematic from a staff management perspective, particularly if significant

effort has already been invested.

The NEPA process: two faces of NEPA—

The NEPA may be viewed as both (a) a process to be managed and (b) as a risk

factor in the management of other unit processes. With regard to NEPA as a process to manage, rangers may tend to refer to the “NEPA Triangle” as a normative

or prescriptive basis for structuring and guiding the work required to move a project through its NEPA elements (fig. 1). However, the linear approach to project

development suggested by the NEPA process may not describe well the actual

process by which project concepts evolve and are carried through to a decision and

implementation.

Rangers may engage in an iterative process by which a project concept is

narrowed and sharpened through several cycles (fig. 2). Some of these cycles may

include the development, review, and refinement of, for example, an environmental

analysis to improve project factors such as clarity, feasibility, and information

content. Reducing sources of uncertainty may be a key aspect of the iterative

process. Ranger management of the process and interactions with staff during the

process may serve as a basis for ranger confidence in the overall decision process.

Communication between the ranger and the various staff specialists involved in a

project may make up a significant portion of the effort associated with developing

a project and carrying it through the NEPA process.

The process of project iteration may be reflected in changes to the scope and

complexity of project, with the project sometimes growing larger and then smaller

in response to the influence factors discussed above. As the project begins to center

on the appropriate scope and complexity, a consensus is approached by line and

staff that the project is “right.” From a management perspective, it is perceived

desirable that a window of time is allowed for this to take place, and projects

“When a specialist is

a part of a team and

they know that their

ideas are valuable,

the risk of being

careless goes down

substantially.”

“The uncertainty that

causes me to pause

before I make a decision . . . is the background that shows how

(the staff) got to the

findings.”
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GENERAL TECHNICAL REPORT PNW-GTR-766

Figure 2—Iterative model of project development.

Figure 1—The NEPA Triangle. (Source: USDA Forest Service 2007).
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Factors Influencing Line Officers’ Decisions About National Environmental Policy Act Project Design and Development

should not be developed too quickly nor take too long. Projects that settle on an

equilibrium too quickly are perceived to be at risk owing to insufficient planning

and thought. Projects that take too long may have entered into, for example, areas

of analysis where staff cannot agree upon the nature or scope of impacts.

The NEPA is often viewed as a risk factor in the management of other unit

processes. The uncertain outcome of the NEPA process (e.g., no appeal, appeal,

litigation) may result in a significant time lag between when a project is conceptualized and when it is finally implemented. In some cases, the project may not move

forward at all. These outcomes can result in both economic and noneconomic

impacts to the unit. These are discussed in more detail below.

The “NEPA sieve” and project selection—

National Environmental Policy Act considerations influence project selection at the

earliest stages, and tend to be used as a first-cut NEPA sieve to determine which

projects to move forward in the NEPA process. Line officers may differ in how they

structure and apply the NEPA sieve. Public land managers have considerable flexibility in how a project proposal is designed and may use this discretion to design a

project that has greater social acceptability (Laband et al. 2006). Projects may be

divided into two, three, or perhaps four categories as part of an initial screening and

selection process, with one category for projects that are deemed unlikely to make it

through the NEPA process.

The remaining categories may define projects that require, to varying degrees,

line officer involvement as part of the overall development approach. In these

cases, line officer involvement may include significant efforts to garner additional

sociopolitical resources, or efforts to involve higher level unit management (e.g.,

forest supervisor) to obtain, for example, broader ownership for the project.

Rangers will at times and under varying conditions undertake relatively highrisk NEPA projects. Management strategies for these projects include (a) careful

attention to project definition and scope, (b) additional communication with staff

members to clarify its high-risk nature and to improve staff ownership for the

range of potential NEPA-related outcomes, and (c) additional interaction and

communication with agency and nonagency stakeholders.

Definitions of risk in project selection and development—

Risk is a central consideration in the management of many activities and enterprises.

From a technical standpoint, risk is generally conceptualized in terms of two components: a potential consequence or loss, and the probability or likelihood that the

potential loss will occur. The result is a definition of risk based on the principle

“I’m pretty sure this

is the right way to go,

but would another

person looking at the

same (environmental

analysis) but without

the knowledge I have,

come to the same

conclusion?”
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GENERAL TECHNICAL REPORT PNW-GTR-766

of expected value, by which the loss is multiplied by its associated probability of

occurrence to provide a measure of risk (Kaplan and Garrick 1981). By this measure, risk is the probability-weighted value attached to a negative outcome or loss,

the determination of which involves two dimensions: one associated with the consequence itself, and the other associated with its likelihood.

Because virtually all human activities involving decisionmaking have uncertain

outcomes, and outcomes have the potential to result in loss, risk is an important

consideration in decisionmaking independent of whether it can be formalized in

terms of the expected value calculus noted above. Indeed, from a large body of

research spanning a great number of decisionmaking domains, it appears that

although people consider risk in their decisions, there is little evidence that they

do so according to a technical standard of risk (Montgomery et al. 2004). Line

officers are no exception in this regard, even though the concept of risk is one they

consider and is a term that they use regularly to describe how they evaluate project

decisions.

In real-world decision problems, matters of risk often become complex.

Technical approaches can be applied to complex problems to yield structured and

quantitative models of risk (Haimes 1998). However, these can be costly and time

consuming to develop even when all of the factors are known. From an informal

standpoint, risk can be considered in terms of a multidimensional framework by

which different risk factors are evaluated as part of decisionmaking. For natural

resource managers, one form of risk assessment pertains to risks to the natural

resource base, which we will refer to here as resource risk. Resource risk is any

potential loss to the natural resource base. In essence, resource management has as

one of its principal goals the management of resource risk through its various monitoring and intervention processes. Potential losses to the resource base can result

from natural disturbance factors such as fire, disease, and noxious vegetation. It can

also result from human activities such as arson or chemical releases from mining

operations. Active management to control such factors and their effects on the resource base constitutes risk management, a process that involves the identification

of risk sources, an assessment of their impacts on the resource base, the determination of a desired adjustment to the risk, and the development and implementation

of an appropriate management response.1

 One form that management response to

resource risk can take is projects developed and implemented with the objective

1

 For a more detailed discussion of risk management as applied to ecosystem management,

see Cleaves and Haynes (1999).

For natural resource

managers, one form

of risk assessment

pertains to risks to

the natural resource

base, which we will

refer to here as

resource risk.

“I think that as line

officers what we’re

really called upon to

do is manage risk.”

“A lot of it comes down

to what is it that’s going

to move the resource

in the direction it ought

to be moved; the best

weighing of process

risk against resource

risk.”
13

Factors Influencing Line Officers’ Decisions About National Environmental Policy Act Project Design and Development

of taking action on the land to reduce resource risk or manage the level of risk.

Such projects are almost always subjected to the NEPA process before they can

be conducted.

The NEPA process itself poses uncertainties to the management of resource

risk, as the ultimate approval of a NEPA project is influenced by judicial and

administrative factors that are out of the direct control of the line officer and unit

staff. Should a project fail for either judicial or administrative reasons, the potential benefits in terms of resource risk management (e.g., risk reduction) are lost.

The overall evaluation of projects with respect to the challenges posed by

NEPA involves an assessment of process risk. Process risk is the potential for a

project to fail owing to one or more of the process elements associated with NEPA.

In practice, this is often conceptualized to be the litigation and appeal aspects of

NEPA whereby the courts and other administrative bodies are afforded the opportunity to oppose a project. Process risk can also be associated with the analytic requirements for a NEPA project and the inability of the unit to adequately identify

and scope an environmental analysis such that the project rationale is coherent. A

portion of projects requiring a NEPA analysis (i.e., EA or Environmental Impact

Statement [EIS]) are entered into but not completed on account of various problems associated with staffing levels, loss of project continuity during analysis,

changing environmental conditions, changing sociopolitical conditions, and changes

in unit management.

Process risk is an informal assessment. At present, the agency has no formalized basis for assessing process risk and does not have a common definition among

district rangers. Terms such as litigation risk and implementation risk are also used

to convey the notion that the NEPA process, both directly and indirectly, exposes

the unit to the potential for loss. How process risk is assessed may differ from one

ranger to another, and from one time to another for a given ranger depending on

several factors, including (a) the particular type of project being considered (e.g.,

fire salvage, recreation, stream restoration), (b) staff capabilities and experience,

(c) the past and present sociopolitical climate, (d) past and recent court rulings,

and (e) the management context within which the ranger is currently working (e.g.,

forest, region, agency). Because of this, the assessment of process risk is subjected

to many sources of variability, all of which contribute to a lack of consistency in

how NEPA projects are developed.

Process risk is considered early in the project selection and as well during the

entire project development. At different times in project development the assessment of process risk can take on alternative characterizations. For example, a

“You’ve got to weigh

your resource risks

very carefully; you

want to make the

right decisions on the

resource. That’s our

primary job. The

process risk you take

is to go through the

process in such a way

that you get to do the

right thing on the

ground as a professional.”

Process risk is

considered early in

the project selection

and as well during

the entire project

development.
14

GENERAL TECHNICAL REPORT PNW-GTR-766

project idea or concept may be evaluated initially in terms of its essential survivability through the NEPA process, with high-risk projects being rejected. At other

times in the project development cycle, process risk vis-a-vis NEPA, may be pitted

against other risks that are associated with unit management. For example, disciplinary compartmentalization could make it difficult to develop cross-disciplinary

communication in project development. Staging projects to reduce complexity

exposes the line officer to the risk that some staff specialists may perceive themselves as left out of the project development cycle, or that their particular specialty

is underappreciated in terms of its role in resource management. Attempting to be

excessively inclusive of staff specialties in the development of a project could

increase its complexity (and its NEPA process risk) but may decrease the risk of

staff alienation. Significant management resources in terms of ranger and staff time

may be applied to the management (and minimization) of process risk. This is

discussed in more detail in a later section.

Process risk and potential losses to the unit—

Process risk arises because the NEPA process directly and indirectly exposes a unit,

its staff, and its management to the potential for significant losses, both economic

and noneconomic. These losses can take various forms.

One form of loss is that associated with opportunity costs. Opportunity costs

(or losses) occur when one project is chosen for development over another, but

the chosen project fails to be implemented owing to NEPA-related factors. The

anticipated value of the foregone project represents an opportunity loss in that the

benefit of the project is not realized. In addition, if the upfront development costs

or investment for the chosen project is greater than the unchosen project, then that

difference is lost as well. Opportunity costs are not formally evaluated in the

agency. Although some rangers consider opportunity costs in selecting projects for

development and for carrying through the NEPA process, there appears to be no

formalized assessment of these costs in considering the overall value of pursuing

one project over another.

 Loss or delay of funding owing to the NEPA process may be a significant loss

to a unit. Many projects carry with them a revenue stream when the project is implemented. These revenues may be required to support, for example, staff operations as well as general facility expenses. The loss of revenue owing to a failure of

the project in the NEPA process can have financial impacts on a unit. For example,

maintaining consistency in staff full-time equivalents is an important management

consideration for district rangers. Variation in unit funding can affect a unit’s staff

budget, with resulting changes in the unit’s staffing profile.

“(The) project that’s in

litigation and negotiation now is 11 years

old. My fear with the

settlement is that the

ground has changed

and we’re negotiating

it on an 11-year-old

NEPA document that

doesn’t represent

what’s out there anymore. Over that length

of time I lost the original players. I’m the

only original player.”

“If it’s an analysis you

have to go back into,

it’s a whole lot of time

and effort that could

have been spent

creating something

that was going to

actually happen on

the ground.”
15

Factors Influencing Line Officers’ Decisions About National Environmental Policy Act Project Design and Development

Maintaining unit and staff morale is critical to maintaining the capabilities

needed to succeed in resource management. Modern resource management is a

team endeavor and requires the cooperative efforts of a cadre of disciplinary

specialists as well as guiding management to fulfill the multiuse mission of the

agency. Achieving a high level of team cooperation and efficiency necessitates a

concomitantly high morale. The failure of projects in the NEPA process can lead

to low morale. A sense of loss may occur if, for example, a canceled project is

perceived as an indicator of the unit’s capabilities. It may also occur if the unit has

a high level of investment in implementing the project and a strong desire to see

action taken on the ground. Line officers may be particularly sensitive to this issue

and may avoid projects that could lead to disappointment. Although the loss of a

single project to NEPA-related factors may have relatively little impact on unit

morale, repeated or successive project failures can be problematic from a staff

management perspective.

The line officer’s perception of his or her image as an effective leader and

manager may play a significant role in the decisions they make with respect to

project development and the NEPA process. With respect to staff, line officers

may actively seek to maintain a positive image as a good leader who makes sound

decisions about project selection. With respect to nonagency stakeholders and the

general public, line officers may desire to be seen as exemplifying high-quality

leadership with regard to resource management decisionmaking. Losses owing to

elements of the NEPA process, and particularly appeals and litigation, may be seen

as compromising their image as an effective leader and manager. This is an aspect

of the line officer role that may be underappreciated in the realm of NEPA as a

disclosure process. In general, many of the “soft” elements of unit management

may be underappreciated and need to be discussed more fully.

Approaches and strategies for management of process risk—

How risk management is approached will depend on a number of factors, including

the level of risk that is acceptable to a manager. Acceptability is a varying concept

and will depend on the risk attitudes of an individual, as well as the ways in which

risk-based decision problems are analyzed and framed (Fischhoff et al. 1981). Risk

management can be seen as an adaptive management response to situations in which

there is a potential for loss. In general, people seek to maintain equilibrium with

respect to risk and will exercise management actions that are consistent with adjusting their present risk conditions to a level that represents a desirable or target level

of risk (Wilde 2001).

“Staff morale is a

huge factor. I leave

(a project) open for

everybody to hook on

and have some ownership. . . The range of

alternatives is how I

think everybody is

able to hook on (to the

project) and own it.”

“You lose a lot of face

if you fail with your

analysis.”
16

GENERAL TECHNICAL REPORT PNW-GTR-766

Risk management is a cyclical process that involves (a) assessment of risk, (b)

comparing perceived to desired level of risk, (c) determining the required risk adjustment, (d) selecting a risk management strategy, (e) implementing the strategy,

and finally (f) monitoring and evaluating the result (fig. 3). Active management of

process risk involves all of these steps in one form or another, though they may not

be open and explicit, and may take on a different form in different situations and

by different line officers.

A general strategy can be described in terms of a dynamic risk assessment

and management model in which managerial experience and style forms the basis

for a desired level of process risk. This level of process risk is compared with a

perceived level of process risk to yield a risk adjustment. One or more strategies

for process risk management are selected and applied, with the outcome monitored

in terms of its impact on perceived process risk. The feedback loop in the model

operates to bring about and maintain a concordance between the desired level of

process risk and the level of process risk that is perceived to exist. The effectiveness of the model is contingent upon a number of managerial factors, including

the personal risk attitudes of the manager (e.g., risk taking, loss aversion), the

decisionmaking skills and style of the manager, and ability to implement the

management strategy.

In general, active management of process risk can be accomplished by several

means, including:

• Rejection of high process risk projects: Line officers may reject projects

for consideration that are perceived to have excessively high process risk.

The strategy by which this assessment is made may not be consistent across

rangers. Projects that are rejected may include activities such as fire salvage, road construction, projects in roadless areas, projects in threatened and

endangered species areas, and old-growth logging. However, there appear

to be no universally defined criteria for high-risk projects, and one ranger

may undertake a project that another ranger would not. The judgment that

a project is too high-risk to undertake may have important perceptual

qualities that differ depending on such factors as the capability of staff,

current conditions with respect to stakeholder concerns, and the relative

benefits of implementing the project.

• Decreased project scope and complexity: More complex projects, such as

those attempting to accomplish multiple resource objectives under a single

project umbrella, may be seen by some rangers as exposing them to greater

“My strategy is to

manage a process so

that the controversy is

simply a difference of

opinion on what the

right answer is; it’s

not based on analysis

differences. I don’t feel

a lot of uncertainty

when I’ve been active

in that process.”
17

Factors Influencing Line Officers’ Decisions About National Environmental Policy Act Project Design and Development

risk by allowing more opportunities for project opponents to identify technical and procedural weaknesses or flaws. Rangers may avoid programmatic or landscape-scale projects if they perceive that such projects

introduce complexities (e.g., cumulative impacts) that could lead to delay

or rejection of the project as part of the NEPA process. This strategy may

come into conflict with other agency principles or concepts such as programmatic project development, landscape-scale project development, and

ecosystem-scale project development.

• Increase the depth and rigor of environmental analyses: An important

and often-used strategy for process risk management is to increase the level

of effort applied to NEPA-related documentation, particularly environmental analyses. This may occur as part of an initial environmental assessment in response to perceived process risk, or in response to a successful appeal by project opponents. From the standpoint of process efficiency,

a key concern here is the potential for a “sunk-cost effect” to occur with

respect to a NEPA project and its associated analysis. A sunk-cost effect

occurs when additional resources are expended on a project beyond what

would have been spent if that amount had been known beforehand (Arkes

and Blumer 1985, Arkes and Hutzel 2000). The result is a continuous

increase in resource expenditures (e.g., staff time) on, for example,

deepening and refining an EA to a level that would not have been considered reasonable and justifiable were that amount of depth proposed at

Figure 3—Dynamic model of process risk assessment and risk management.
18

GENERAL TECHNICAL REPORT PNW-GTR-766

the beginning of the project. Sunk-cost effects occur because of a judgmental bias arising from how people evaluate prospects that involve a

sure loss (i.e., the sunk cost already expended) against the possibility

of avoiding that loss by expending additional resources (Kahneman and

Tversky 1979). The sunk-cost effect tends to amplify the perception of risk

associated with the project, and the need to take action to reduce and manage that risk. Managing the appropriate level of depth in an analysis can be

of key concern to a line officer, and staff may be of the opinion that more

analysis is appropriate than the line officer believes is required. Management of process risk carries with it additional risks that express themselves

in terms of line and staff relations.

• Portfolio development: Rangers may seek to manage process risk by

developing portfolios of projects that provide a form of diversification with

respect to, for example, process risk. The concept of risk diversification is

a central feature of modern portfolio theory, and in efficient portfolios,

overall portfolio risk is reduced by managing for uncorrelated risk in the

portfolio mix. Uncorrelated risk means that should one project or prospect fail, that failure is not linked or correlated to the potential for failure

of other projects in the portfolio. In essence, all of one’s eggs are not in

one basket. For portfolio development to meet its desired ends, the portfolio developer must be careful to assess the respective risks of each of

their projects or investments and determine to what degree the risk is from

a common source (systematic risk), and to what degree the risk for each

project is unrelated to that for other projects (specific risk).2

 It is unclear

how this strategy is operationalized by district rangers and whether their

intuitively constructed portfolios are indeed reducing overall portfolio risk,

or whether their portfolio collections of projects are correlated with respect

to risk, in which case overall risk may be increased.

• Decomposed and staged plans of work that involve sequential projects:

Breaking down relatively large resource management plans into smaller,

less complex projects is one approach rangers may take to reduce process

risk. However, some rangers may have experienced difficulties with this

approach if a significant number of small projects interact to produce

cumulative impacts that are only observable by examining the entire set

2

 For the historical derivation of portfolio theory, see Markowitz (1959). For an accessible

discussion of portfolio theory in the context of modern economics, see Bernstein (1998).

“Specialists don’t

always feel that line is

taking into consideration their input. So,

my role as a line officer

is to develop the skills

to make all the input

valuable.”
19

Factors Influencing Line Officers’ Decisions About National Environmental Policy Act Project Design and Development

of projects. Likewise, the staging and timing of small projects may be

difficult to rationalize, thereby increasing the process risk associated with

the overall set of projects. Planning approaches used by ranger districts

may or may not give adequate consideration to the interactive and cumulative effects of small projects. This strategy for managing process risk can

be seen as a form of portfolio development where a given project is segmented into a series of smaller projects. Here, the problem of correlated

risks may be important to evaluate, particularly if the failure of one segment leads to the failure of others. In risk assessment, this is known as

common-mode failure: a tendency for separable portions of a system or

project to be represented as having independent failure probabilities when

in fact an underlying common-cause failure potential is present.

• Categorical exclusion (CE) bundling: Under some circumstances rangers

may use the CE approach to bundle a number of small projects into an

overall project that may be marginally appropriate for the CE designation.

This approach may actually increase process risk (particularly with respect

to the agency internal NEPA review process in that the characteristics of

the project could warrant an EA) in favor of potentially reducing risks to

the natural resource base. Some rangers may view the internal NEPA review process as a separate source of process risk. This management strategy

has a proactive stance toward accomplishing work on the land. It is highly

dependent upon an individual ranger’s risk-taking propensity, tolerance for

risk, and perception of the downside associated with an unfavorable review

of their use of the CE mechanism.

• Early and extensive involvement of nonfederal stakeholders: Rangers

may engage a variety of publics as part of both defining project scope and

building stakeholder agreement as a strategy for reducing process risk.

Publics engaged may include the general public as well as particular constituencies that could or do have objections or concerns about a (potential)

proposed management action. Nonfederal stakeholders also may be engaged as part of a general discussion or elicitation of views about resource

management and, for example, community needs that can be satisfied by

unit-initiated projects.

Barriers to NEPA process efficiency—

The staging and management of staff work may be an important contributor to

NEPA process inefficiencies. Staff specialists are called upon for a variety of tasks,

“I tend not to select

projects that will take

years and years to do.

By the time you take a

5-year project and put

the decision out, you

got some issue that’s

hit and your analysis

has failed. I look at

projects that are

efficient and can be

done in smaller

chunks.”
20

GENERAL TECHNICAL REPORT PNW-GTR-766

of which NEPA-related analyses are only one. Interruptions in the analysis process

may produce significant gaps in staff workflow, possibly leading to inefficiencies

when staff must start-stop-restart, for example, an EA.

Obsolescence before completion occurs when an analysis takes such a long

period of calendar time that critical assumptions or information in an analysis are

no longer valid and the analysis has to be started anew. Staff turnover on longrunning analysis can require redoing all or significant parts of an analysis.

The distribution of NEPA expertise is not uniform across management units.

Although some ranger districts may have a key NEPA staff member, others may

have to rely on either a shared resource at the forest (or higher) level, while still

others may have NEPA expertise that is on the margin of being outdated.

Risk attitudes differ across rangers and management situations. The incentive

structure and value for taking risks as part of management decisionmaking is not

always clear. A 2005 study of line officers’ perceptions of agency values found that

risk taking and innovation were among the least rewarded values (Kennedy et al.

2005). National Environmental Policy Act projects represent opportunities for innovation as well as potential exposure to risks. How innovation is rewarded, and

line officers are indemnified or protected against losses to their unit associated

with the NEPA process, will be a factor in determining both the projects that they

choose to develop and the methods they use to help ensure that they and their unit

do not experience loss associated with process risk.

Line officer decisionmaking and the NEPA process—

Line officers may differ in how they define and describe their decisionmaking

process. For some line officers, the decision regarding which project alternative to

propose may be made very early in the project development process. In some cases,

the line officer may have a particular (and focused) management action in mind

from the very beginning of project development and through the NEPA process.

This tendency may interact with the characteristics of a particular project or type of

project, and a given line officer may not be consistent in the degree to which their

initial formulation of a project focuses on a clearly identified and preferred management action.

For other line officers, the decision regarding which project alternative to propose may emerge from the NEPA process and their interaction with project staff

during the development of NEPA documentation. They may begin a project with a

generalized sense or idea of a desirable management action, and use pre-NEPA as

well as NEPA process interactions with staff to refine and hone their preferred

alternative.

“The reason NEPA

takes a lot of time is

because we have our

specialists busy on

so many things and

so spread out that it’s

hard for them to focus

on a project, get it to

a certain point, and

then move on and

do something next.

They’re constantly

interrupted by other

priorities.”

“Part of the job that I

have to do is balance

what we have available

as far as total resource

and budget, and how

much of a risk a

particular resource is

in the big picture.”

“I want a really good

reason to be doing

this. I don’t want a

sloppy, uncertain

reason to do this.

I want confidence that

it’s worth it.”
21

Factors Influencing Line Officers’ Decisions About National Environmental Policy Act Project Design and Development

Still other line officers may view the best decision in terms of what actually

gets implemented and may take a larger perspective on the NEPA process that

includes appeals and litigation as additional elements that shape and define the best

alternative to pursue. In these situations, line officers may be less concerned about

overall process risk and may work to move projects through to a decision more

quickly. These line officers may view the overall NEPA process, including its

judicial appeal and review elements, as a negotiation process in which multiple

cycles of planning, proposal development, public scoping and judicial review are

needed to produce a final, implemented project. For these line officers, a successful

project may be defined in terms of a socially acceptable outcome that meets the

needs and values of a variety of stakeholder perspectives.

Decision confidence is of significant importance to line officers, as they must

speak for the project to audiences and constituents both inside and outside of the

agency. Line officer management of the NEPA process and the work of their staff

is a significant source of confidence in decisionmaking and goes beyond the information content of the NEPA documentation (e.g., EA). Line officers may have

only general familiarity with the detailed information and analytical content of, for

example, an environmental analysis, and rely upon their staff specialists as well as

their confidence in those specialists as disciplinary experts to support their conclusions about the soundness and rigor of the analysis. Familiarity with and control

of the management process by which an environmental analysis is created provides

assurance that the chosen management action is the best action from all possible

actions that could be proposed.

Summary and Recommendations

This exploratory study used interviews with district rangers to identify concepts

that may be of use in understanding how resource management projects are initiated and developed, and how management activities associated with project development may be influenced by aspects of the NEPA process. The application of

more rigorous and structured methodological approaches is needed to determine

the validity and utility of the concepts identified here. These approaches could

include interview-based methods that explore indepth the management experiences

of individual rangers. If there is a single message that can be delivered from this

initial work it is this: enormous variability may exist in the district ranger population, some owing to context, some to individuals’ backgrounds and management

styles, and some to how the complexities of managing a ranger district are interpreted and applied to resource management decisionmaking. At a minimum, a

“The process that you

went through to produce it is where you

get the confidence in

the EA.”

“The main thing (for

me) is knowing . . . the

decision I’m about to

make is supported by

all the specialist input

and what I know.”
22

GENERAL TECHNICAL REPORT PNW-GTR-766

census is needed to determine the extent of this variability and its impact on how

projects are developed. Survey-based approaches using either traditional, mail-out

survey methods or Web-based protocols can be used to conduct such a census.

The present study has identified a number of concepts that offer potential value

for further research. The concept of process risk may be an important assessment

that guides many of the decisions associated with selecting, conceptualizing, developing, and analyzing NEPA projects. This rich and informal assessment has no

standardized guidelines and is subjected to some of the same sources of variability

that may be inherent in other dimensions of the ranger population. How individual

rangers conduct this assessment and apply its results will influence the projects they

choose to pursue, and determine those that they reject. How they gauge the risks to

themselves and their unit associated with the NEPA process and how they manage

those risks will be an important driver in the efficiency they are able to attain in

moving projects from an initial starting point through the NEPA process to useful

action on the ground.

The concept of the NEPA triangle (fig. 1) as a metaphor for carrying out the

NEPA process in the context of unit management may not reflect (a) the complexities of addressing the multiobjective nature of unit management, which includes

management of human resources, financial resources, and natural resources and (b)

the way in which district rangers actually do their work in concert with their staff

and their upper level management. The linear representation of the NEPA process

portrayed by the NEPA triangle does not account for the nonlinear and iterative

approach that district rangers (often) use to accomplish the development of a project, its required documentation, and the consensus-style management that is often

used to bring both line and staff into agreement about the best management alternative to pursue for a given project. In addition, the NEPA triangle has significant but

unacknowledged hooks or linkages to other important elements of the larger NEPA

process that includes appeals and litigation, the outcomes of which have important

consequences for unit functioning.

Prior to the existence of NEPA, district rangers had considerable latitude to

make resource management decisions and execute resource management plans

with relatively little encumbrance by documentation and process requirements

or by the need to work collaboratively with nonagency stakeholders. One of the

adaptive management responses to NEPA has been for the ranger cadre to move

from a command-and-control style of management to a consensus style of management that requires rangers who are more skilled and comfortable with a highly

interactive management style that focuses on process, inclusion, and collaboration.
23

Factors Influencing Line Officers’ Decisions About National Environmental Policy Act Project Design and Development

Research has pointed out that although rangers still oversee projects on the ground,

they also serve as facilitators of public dialogue about forest management policy

within their communities (Apple 1996, Tipple and Wellman 1991).

A consequence of the distributional change in the amount of unit work that is

needed to support process-related activities, such as meetings, written communications, documentation, stakeholder outreach, and the like results in an adaptive shift

in how line management candidates are selected and developed. Today’s ranger

population may be more oriented to the planning and analysis aspects of project

development than yesterday’s rangers, who were more inclined toward action and

outcome cycles and for whom the ideal decision tempo was more fast paced.

Ideally, these two concepts can be merged into an efficient amalgam of process

sensitivity, collaborative project development, and adaptive management that

emphasizes the need for focused action and response cycles.

Although the NEPA document itself was not a focal point of this study, it is a

significant factor in the overall cost, efficiency, and outcome of the NEPA process.

Since the inception of NEPA, the documentation process has expanded considerably, with today’s NEPA documents containing highly detailed analysis of project

alternatives and their impacts. But what of the need for the project in the first place

and full consideration of the “no action” alternative? Has NEPA documentation

kept pace with the need to inform a broad constituency, including the general

public as well as specialized readers such as congressional staffers, about the value

and benefit of a project or a program of work? More broadly, on whose behalf is

the NEPA analysis and documentation done? Who is the audience? There is reason

to believe that in the maelstrom of NEPA documentation requirements, these

fundamental questions of audience have gotten misplaced, if not lost. The need for

a project is a significant aspect of how many organizations develop their environmental reporting documentation.3

 Some organizations have adopted a model of

developing highly readable executive summaries in which the need for the project

forms a core for communicating an environmental analysis.4 We propose greater

3

 Private industry must comply with environmental reporting requirements for many of

their projects. For example, some states have environmental disclosure requirements

modeled on NEPA. Need for a project is a key element of many private industry environmental analyses. The “no action” alternative may be richly developed in terms such as

projections from current conditions to points in the future both without and with the

project under consideration.

4 The National Aeronautics and Space Administration has for some of its NEPA documents

developed focused and highly-readable executive summaries that synthesize the content of,

for example, an EIS and at the same time articulate the need for action. The intended

readership for these documents includes the general public as well as, for example,

congressional staffers.
24

GENERAL TECHNICAL REPORT PNW-GTR-766

emphasis on “need for the project” in analysis, and a much richer description of the

projected impacts of the “no action” alternative. The NEPA document needs to be

more synchronized with the needs, interests, and capabilities of specific audiences

and readerships, including general and specialized publics, congressional staffers,

the judiciary, and the media at large. Focused effort needs to be placed on reviewing and identifying how NEPA documentation could be improved as a vehicle for

communicating and furthering the agency’s multiuse mission.

Many of the challenges the agency faces today in terms of the NEPA process

arise, in part, from the contentiousness that is experienced in the public arena with

respect to the desirability of proposed agency actions. A significant part of this

discord arises from differences of opinion concerning the value of active management of natural resources. Not everyone agrees that active management of natural

resources is desirable. For some, human intrusion into natural processes is objectionable and they prefer passive management, by which nature is allowed to take

its own course. But, belief in the desirability of active management is a predicate

for a positive response to a NEPA project proposal. At the extreme of disbelief,

all NEPA projects are rejected on principle. For those in the middle, which is the

broad public and nongovernmental organization stakeholder constituency, “active”

may have varying definitions and may be fluid depending on the circumstances.

In these cases, which are the majority, the agency has an opportunity to define its

position and the value of active management of natural resources. It must take this

opportunity each time it is available and not assume that the value is firm and consistent in the minds of stakeholders. One of the more available places this challenge

can be met is in NEPA documentation and through the NEPA process.

Acknowledgments

Support for this project was provided by the USDA Forest Service, Pacific Northwest Research Station, Focused Science Delivery Program under Agreement No.

06-JV-11261976-297 to MacGregor-Bates, Inc. A preliminary version of this paper

was presented at the NEPA for the 21st Century, Workshop on Integration of NEPA

Processes, Stevenson, WA, March 19-22, 2007. We would like to acknowledge the

various reviewers for the publication as their comments provided clarity on several

issues and enhanced the final product. Reviews were completed by individuals with

a scientific and research background as well as individuals with a land management

and line officer background. We would like to extend our sincere gratitude to the

individual line officers who provided us the benefit of their knowledge and extensive experience in support of this study. They are listed below with their unit
25

Factors Influencing Line Officers’ Decisions About National Environmental Policy Act Project Design and Development

association at the time of their interview: Ken Anderson, Wallowa-Whitman

National Forest, Whitman Unit, Baker City, OR; Bill Anthony, Deschutes National

Forest, Sisters Ranger District, Sisters, OR; Dave Campbell, Bitterroot National

Forest, South Fork Ranger District, Darby, MT; Erin Connelly, Rogue River

National Forest, Applegate Ranger District, Jacksonville, OR; Roberto Delgado,

Six Rivers National Forest, Mad River Ranger District, Mad River, CA; Cliff Dils,

Umpqua National Forest, Roseburg, OR; Doug Gochnour, Boise National Forest,

Idaho City Ranger District, Idaho City, ID; Chuck Hagerdon, Cibola National

Forest, Mt. Taylor Ranger District, Grants, NM; Lisa Krueger, Flathead National

Forest, Tally Lake Ranger District, Whitefish, MT; Cindy Lane, Clearwater National Forest, Kooskia Ranger District, Kooskia, ID; Maggie Pittman, Lolo National Forest, Missoula Ranger District, Missoula, MT; Alan Vandiver, Klamath

National Forest, Happy Camp and Oak Knoll Ranger District, Happy Camp, CA.

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