On July 31, the Center for Progressive Reform submitted a public comment for a proposed rule from the U.S. Department of Agriculture (USDA) to amend regulations governing the U.S. Forest Service. USDA proposed a redefinition of the Forest Service Directive System, which traditionally comprised both the Forest Service Manual and Forest Service Handbooks. Simply put, the Manual sets out what the Forest Service must do to manage national forests, and the Handbooks provide technical expertise and guidelines for how to accomplish those things.
Currently, both the Manual and the Handbooks are mandatory documents. Under the proposed change, the Manual will remain the only mandatory direction for the agency. The Handbooks, on the other hand, are scheduled for a substantial downgrade in authority. They would be reclassified as purely “advisory and informational guidance,” from which agency employees could deviate without any requirement for documentation or justification.
Taken altogether, the changes aim to fundamentally restructure the Forest Service’s internal guidance system, recalibrate public engagement for policymaking, and undermine the guardrails that ensure agency actions follow evidence-based procedures that would reduce arbitrary decisions and special interest capture. Although this action has been publicly defended as seeking to grant greater discretion to agency employees in program execution, in reality, it intends to redefine requirements for the agency’s standards, criteria, and guidelines, as well as the scope of public notice and comment. These changes will deepen the debate over administrative flexibility versus transparency and evidence-based policymaking in federal land management that the administration has been pushing since early 2025.
In our comment, we urged the Forest Service to withdraw this proposal and preserve public scrutiny over agency actions, whether they appear in the Manual or the Handbooks, which goes in line with the agency’s own findings and recommendations from 2018. Then, the Forest Service concluded that its Handbooks contain standards and guidelines that directly affect the public, and it expanded public comment to cover them. Fundamentally, this proposal continues a trend that has seen public participation rights diminished over the last year, which represents a blatant assault on public scrutiny and evidence-based decision-making.
You can read our full comment by clicking the blue button above.
