Response to the journal of forestry article: "uS forest service implementation of the national environmental policy act: Fast, variable, rarely litigated, and declining"

The Fleischman et al. (2020a) article on US Forest Service (FS) implementation of the National Environmental Policy Act (NEPA) correctly identified a decline in the number of NEPA analyses, but several conclusions were not supported by the data used. After analyzing their and other relevant data, we reached substantially different conclusions. Using FS budget data, we found budgets supporting NEPA analyses to be flat to increasing. Likewise, using FS accomplishment data, we found several FS land-management activities increased as others remained flat or decreased. The three types of NEPA analyses took statistically significant different times to complete, and time to complete analyses declined little over 15 years. We also found that litigation rates varied substantially by NEPA analysis type, resource purpose, and FS region. Conducting NEPA analyses is a necessary step in federal land management. However, resources invested in NEPA analyses represent an opportunity cost, and the success of the FS is better measured by on-the-ground accomplishments rather than number of NEPA analyses produced.