Cutting the Resources Without Cutting the Work

When I was at consultant McKinsey & Co, one of their philosophies in doing cost reduction studies was that you don't cut staffing without first cutting back the work.  Identify the activities that don't need to be done or can be streamlined, change the processes to match, and then cut staffing.

This, of course, is not the way it usually happens, even in good companies.  Most companies just whack staff counts by some percentage, perhaps across the board and perhaps weighted by intuitions as to where the company is fat.  In a good company with good managers and good incentives, the organization can generally be trusted to cut back on the least useful activities in response to the staff cuts.  But in bad organizations with poor incentives, one has no idea if high value or low value activities are being cut.  And in the government, you can almost be assured that when staff and budgets are cut, low-value activities are preserved while high-value core mission activities are cut.  In my world of public parks, staff cuts almost always lead to preservation of bloated headquarters staff while maintenance budgets and staff actually service visitors in parks is slashed.

And then there is this on new rules being imposed by the Trump Administration on NEPA.   If you want to know why infrastructure projects almost never get started and public lands are seldom improved, NEPA is a big part of the reason.  It is something that is desperately in need of reform.  But the Trump Administration appears to be making the same mistake I discussed above, cutting resources without cutting the work required:

Yesterday Greenwire ran a story about how one of the new political appointees at the Department of the Interior issued a memo requiring that National Environmental Policy Act (NEPA) studies (those Environmental Impact Statements you hear so much about) be completed in one year, and be no more than 150 pages long.

If there were ever any doubts that the Trump Administration minions have absolutely no idea what they’re doing, this should put them to rest. Ostensibly intended to “streamline the regulatory process”, blah, blah, blah, its effect will be precisely the opposite; this one memo will delay and stop more projects than anything the environmental community has ever come up with. The activists may be livid, but I promise you that their lawyers are going, “Yee-ha!” I certainly would be if I were still doing NEPA cases.

The NEPA and the hundreds of court decisions interpreting it are painfully clear on how detailed an EIS has to be. Putting artificial and arbitrary limits on an EIS will make it so much easier to show how the EIS does not “take a hard look at the environmental consequences,” contain “a detailed statement of any adverse environmental effects” of a proposed project, etc.


  1. Mercury:

    Seems like the real story here is how the Trump administration's recent actions have exposed how deeply entrenched, strong and redundant environmental regulations and BS actually are.

    The Greenwire guy seems to be saying:

    "Ha! Interior THINKS they have made environmental regulations less oppressive and needlessly onerous for Americans by making it easier to jump through hoop #3 but the law specifically says that all 24 hoops must be jumped through in order, without exception and to the satisfaction of all subsequent hoop monitors! The regs for hoop #3 specifically require that you jump through backwards with your thumb up your ass while incinerating (in a manner pleasing to the other hoop monitors) 10% of your projected construction funds! Just try getting through hoops #4, #5 and #6, let alone #16 without a high score on hoop #3! Mooo...haaa-haaa-haaa-haaaa !!!! "

  2. The_Big_W:

    Well frankly if you can't tell the workers to spend less time on the reports and put less content into them because at every turn someone will just point to the report stating whats missing, then this battle is already completely lost anyway....

    The bureaucracy is perfected when no one can get permission to do anything..... we're almost there!!

  3. Bistro:

    From here it looks like the gvt says laissez faire. You go for it and you tell the govt weenie, observe the new guidance and when they behave exactly like orcs you walk away. Business as usual. Not sure how you lose or the process changed. they're bureaucrats and resistant to change just like cockroaches.

  4. BobSykes:

    We now have over 40 years of case law regarding NEPA and the EIS. The courts do review the content of disputed EIS's, and often reject them for inadequacy. There is no way around producing a detailed, comprehensive EIS for any federally reviewed project, and reduced staffing in the agencies will only further delay projects.

    It should also be noted that every State has its own versions of NEPA/EIS, and the administrations memo doesn't affect them in the least.

  5. stan:

    Hmmmm. Obama unilaterally changed the law without regard to the Constitution, statutes, or case precedents. Apparently, Trump is demonstrably stupid for taking on the status quo.

    Wow. The bias is so overwhelming that logic and rationality have been extinguished.