Forest Service: Proposed Regulations Adequately Address Some, but Not
All, Key Elements of Forest Planning (Letter Report, 09/29/2000,
GAO/RCED-00-256).

Pursuant to a congressional request, GAO reviewed the Forest Service's
forest plan, focusing on the extent to which the Forest Service's
proposed regulations: (1) make clear the agency's mission priorities
before beginning the process of revising a forest plan; (2) link forest
plans to agencywide goals, objectives, and strategies; and (3) hold the
forests more accountable for key elements of forest planning.

GAO noted that: (1) a lack of clear direction on how to resolve
conflicts among competing uses on national forest lands has contributed
significantly to inefficiency and waste in the Forest Service's
development and implementation of forest plans; (2) to address this
deficiency, the agency's 1999 proposed planning regulations would make
ecological sustainability, rather than economic or social
sustainability, the agency's top priority, in order to provide a
sustainable flow of products, services, and other values from national
forests; (3) elevating the maintenance or restoration of ecological
systems over other uses on the national forests is consistent with the
agency's evolving mission, which now favors resource protection over
production; (4) however, the priority assigned to ecological
sustainability is not driven by the statutory authorities specific to
the management of the national forests; (5) rather, it has evolved over
many years, responding, in part, to the requirements in environmental
laws and their implementing regulations and judicial interpretations;
(6) as a result, Congress has never explicitly accepted ecological
sustainability as the Forest Service's highest priority or acknowledged
its effects on the availability of timber, recreation, and other goods
and services on the national forests; (7) the Forest Service has made
some progress in developing goals, objectives, and strategies that help
translate its priorities into on-the-ground projects and activities; (8)
the agency is refining its goals and objectives to better focus on
outcomes and results to be achieved over time; (9) it is also developing
a strategy to reduce the incidence of uncontrollable and often
catastrophic wildfires; (10) yet, even though many of these goals,
objectives, and strategies are to be implemented through on-the-ground
projects and activities governed by individual forest plans, the
agency's proposed planning regulations do not require that these forest
plans be clearly linked to the goals, objectives, and strategies; (11)
in developing and implementing forest plans, national forests have not
always: (a) based their decisions on accurate and complete data; (b)
adequately involved the public and other government agencies throughout
the forest planning process; or (c) lived up to monitoring requirements,
particularly those for monitoring the effects of past planning
decisions; and (12) this has resulted in legal challenges to the plans
and limited the implementation of efforts to expedite the planning
process.

--------------------------- Indexing Terms -----------------------------

 REPORTNUM:  RCED-00-256
     TITLE:  Forest Service: Proposed Regulations Adequately Address
	     Some, but Not All, Key Elements of Forest Planning
      DATE:  09/29/2000
   SUBJECT:  Agency missions
	     Strategic planning
	     Performance measures
	     National forests
	     Forest management
	     Accountability
IDENTIFIER:  USDA National Forest System
	     National Park System

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GAO/RCED-00-256

Report to Congressional Requesters

September 2000 FOREST SERVICE Proposed Regulations Adequately Address Some,
but Not All, Key Elements of Forest Planning

GAO/ RCED- 00- 256

Resources, Community, and Economic Development Division

Lett er

B- 285339 September 29, 2000 The Honorable Larry E. Craig Chairman,
Subcommittee on Forests and

Public Land Management Committee on Energy and Natural Resources United
States Senate

The Honorable Helen Chenoweth- Hage Chairman, Subcommittee on Forests and
Forest Health

Committee on Resources House of Representatives

Since 1976, the Department of Agriculture's Forest Service has been required
by law to develop a land and resource management plan- commonly called a
forest plan- for each national forest or for groups of forests. A forest
plan, among other things, spells out how the agency intends to (1) protect
the lands and resources that it manages and (2) provide goods and services
to the public. Each forest plan must be revised

at least once every 15 years. From 1979 through 1995, the Forest Service
spent over $250 million to develop 123 forest plans covering the 155 forests
in the National Forest System. The agency now plans to spend about $375
million to revise these forest plans and must complete revisions for nearly
three- quarters of the plans in the next 5 years.

The current process used by the Forest Service to develop and revise forest
plans has proven to be costly and time- consuming. National forests spend
tens of millions of dollars a year attempting to develop forest plans that
are legally defensible, scientifically credible, and able to sustain the
forests' resources. Yet, despite these efforts, the agency has often failed
to achieve

planned objectives.

The Forest Service's planning regulations set forth a process for
developing, approving, amending, and revising forest plans. The existing
planning regulations, approved in 1982, 1 have been under revision since
March 1989, 2 when the agency initiated a comprehensive review of its
planning process. In April 1995, the Forest Service proposed new planning
regulations. 3 These regulations were based, in part, on the lessons learned
by over 2,000 people who had participated in or had responsibilities for
forest planning. However, the 1995 proposed planning regulations were never
finalized. The effort to develop new planning regulations began again

in 1997 when the Secretary of Agriculture convened a 13- member
“Committee of Scientists” to take a fresh look at the Forest
Service's planning process and to offer recommendations for improvements.
Primarily on the basis of the Committee's findings, the Forest Service
proposed new planning regulations in October 1999. 4 The public comment
period ran from October 1999 through February 2000. The Forest Service
expects to finalize the new planning regulations early in fiscal year 2001.
Over the last 6 years, we have issued over 2 dozen products that have
identified reasons for- and that have included recommendations to

improve- the cost- effectiveness and timeliness of the Forest Service's
planning process. 5 Concerned about the outcome of the required forest plan
revisions, you asked for our observations on the extent to which the
agency's proposed planning regulations address our prior findings,
conclusions, and recommendations. In this report, we discuss the extent to
which the Forest Service's proposed planning regulations (1) make clear the
agency's mission priorities before beginning the process of revising a

forest plan; (2) link forest plans to agencywide goals, objectives, and
strategies; and (3) hold the forests more accountable for key elements of
forest planning.

1 47 Fed. Reg. 43026 (Sept. 30, 1982). 2 Synthesis of the Critique of Land
Management Planning, Vol. 1, Forest Service (FS- 452, June 1990).

3 60 Fed. Reg. 18886 (Apr. 13, 1995). 4 64 Fed. Reg. 54074 (Oct. 5, 1999). 5
See the related products page at the end of this report for a list of GAO
reports and testimonies on the Forest Service's planning process.

Results in Brief Federal land management is inherently contentious. Our work
has found that a lack of clear direction on how to resolve conflicts among
competing

uses on national forest lands has contributed significantly to inefficiency
and waste in the Forest Service's development and implementation of forest
plans. To address this deficiency, the agency's 1999 proposed planning
regulations would make ecological sustainability, rather than economic or
social sustainability, the agency's top priority, in order to provide a
sustainable flow of products, services, and other values from national
forests, consistent with laws and regulations guiding their use. Elevating
the maintenance or restoration of ecological systems over other uses on the
national forests is consistent with the agency's evolving mission, which now
favors resource protection over production. However, the priority assigned
to ecological sustainability is not driven by the statutory authorities
specific to the management of the national forests.

Rather, it has evolved over many years, responding, in part, to the
requirements in environmental laws- enacted primarily during the 1960s and
1970s- and their implementing regulations and judicial interpretations. As a
result, the Congress has never explicitly accepted

ecological sustainability as the Forest Service's highest priority or
acknowledged its effects on the availability of timber, recreation, and
other goods and services on the national forests. We recommend that the
Forest Service work with the Congress to reach agreement on the agency's
mission priorities. Responding to a draft of this report, the Forest Service
stated that ecological sustainability is absolutely necessary to achieve
other uses on the national forests. However, we believe that until the
Congress and the agency reach agreement on ecological sustainability as the
Forest Service's highest priority, holding the agency accountable for its
performance will be difficult.

In our previous work, we found that the Forest Service has made some
progress in developing goals, objectives, and strategies that help translate
its priorities into on- the- ground projects and activities. For example,
the agency is refining its goals and objectives to better focus on outcomes
and results to be achieved over time. It is also developing a strategy to
reduce the incidence of uncontrollable and often catastrophic wildfires.
Yet, even though many of these goals, objectives, and strategies are to be
implemented through on- the- ground projects and activities governed by
individual forest plans, the agency's proposed planning regulations do not
require that these forest plans be clearly linked to the goals, objectives,
and strategies. We recommend that the Forest Service revise its proposed
planning regulations to require the national forests to clearly link their

plans to the agency's goals, objectives, and strategies and to blend them
with local priorities in revising the plans. According to the Forest
Service, its proposed regulations provide that there be a “direct
link” between forest plans and national strategic goals and
objectives. However, the proposed regulations merely require that long- term
strategic goals, objectives, and outcome measures be
“considered” in managing the national forests, not that they be
clearly linked to the agency's strategic plan. We previously found that in
developing and implementing forest plans,

national forests have not always (1) based their decisions on accurate and
complete data; (2) adequately involved the public and other government
agencies throughout the forest planning process; or (3) lived up to

monitoring requirements, particularly those for monitoring the effects of
past planing decisions. This has resulted in legal challenges to the plans
and limited the implementation of efforts to expedite the planning process.
To hold the forests more accountable for basing their decisions on accurate
and complete data, we previously recommended that the agency revise its

proposed planning regulations to require the national forests to develop
strategies for gathering and incorporating data into their planning
processes. The Forest Service agreed with the desired outcome of our
previous recommendation but declined to revise the planning regulations,

opting instead to revise its system of directives that implement the
planning regulations. While we still believe that it would be preferable to
place requirements in the agency's planning regulations to develop
strategies to help hold forests more accountable not only for gathering and

incorporating data into their planning processes but also for involving the
public and others in the planning processes and for monitoring and
evaluating their decisions, we believe that the Forest Service should, at a
minimum, revise its system of directives to require the national forests to
(1) develop strategies for involving the public and other government
agencies in their planning processes and for monitoring and evaluating

their management decisions and (2) make the strategies available to the
public. Accordingly, we are recommending that it take these actions.

Background The Forest Service, created in 1905, is required to manage its
lands to provide for the sustained yield of six renewable surface uses-
outdoor recreation, rangeland, timber, watersheds and waterflows,
wilderness, and wildlife and fish. In addition, the agency is required by
its guidance and regulations to consider the production of nonrenewable
subsurface resources, such as oil, gas, and hardrock minerals, 6 in its
planning.

The Forest Service is a hierarchical organization whose management is highly
decentralized and whose regional foresters and forest supervisors have
considerable autonomy and discretion in interpreting and applying the
agency's policies and directions, guided by a system of directives
consisting of manuals and handbooks keyed to statutes and regulations. The
agency has three levels of field management- 9 regional offices, 115 forest
offices, and about 600 district offices. Regional offices, each managed by a
regional forester, interpret policy and provide additional direction to the
115 forest offices that manage the 155 national forests. The forest offices,
each managed by a forest supervisor, in turn, oversee some

600 district offices, most of which are managed by a district ranger. The
forest supervisors are primarily responsible for developing and implementing
forest plans for their respective forests. The district rangers are
primarily responsible for implementing project- level decisions-“ on
the

ground activities,” such as harvesting timber, restoring species'
habitats, and constructing campsites- within their respective districts.

The Proposed One of the primary reasons for inefficiency and waste in
developing and

Regulations Would implementing forest plans is the lack of agreement on the
Forest Service's

mission priorities. Federal land management is inherently contentious, and
Establish Ecological parties dissatisfied with a forest plan can cause a
forest to delay, alter, or Sustainability as the withdraw projects and
activities that implement the plan by availing Forest Service's themselves
of the opportunities for administrative appeal and judicial

review that are provided by statute or regulation. To better avoid or
prevail Overriding Mission against legal challenges and to expedite the
forest planning process, we Priority have concluded that the Forest Service
must provide the national forests with clear direction on how to resolve
conflicts among competing uses when developing and implementing forest
plans. Toward this end, the

agency's 1999 proposed planning regulations would make ecological
sustainability, rather than economic or social sustainability, the agency's
6 Hardrock minerals include gold, silver, lead, iron, and copper.

top priority, in order to provide a sustainable flow of products, services,
and other values from national forests, consistent with laws and regulations
guiding their use. Elevating the maintenance or restoration of ecological
systems over other

uses on the national forests is consistent with the agency's evolving
mission, which now favors resource protection over production. From 1979,
when the first forest plan was approved, through the late 1980s, the agency
emphasized timber production over other uses on the national forests. Hence,
the national forests emphasized timber production in many

of their forest plans. However, the Forest Service has shifted its mission
priorities away from producing timber and other commodities toward
maintaining or restoring land health and forest resources. For example, the
Forest Service's fiscal year 2001 budget justification, submitted to the
Congress in February 2000, states that “land health is the agency's
highest priority” and that the proposed budget would allow the Forest
Service to accomplish its “conservation mission.” 7 Although the
Forest Service's 1999 proposed planning regulations would

make ecological sustainability, rather than economic or social
sustainability, the agency's top priority, the priority assigned to
ecological sustainability is not driven by the statutory authorities
specific to the management of the national forests. These authorities
provide little direction for the agency in resolving conflicts among
competing uses on its lands. Rather, the priority assigned to ecological
sustainability is predicated on the requirements in environmental laws-
enacted primarily during the 1960s and 1970s- and their implementing
regulations and judicial interpretations. These laws reflect changing public
values and concerns

about the management of the national forests as well as increased scientific
understanding of the functioning of ecological systems and their components.
In particular, section 7 of the Endangered Species Act represents a
congressional design to give greater priority to the protection of
endangered species than to the other missions of the Forest Service and
other federal agencies. 8

Because the priority assigned to ecological sustainability has evolved over
many years, responding, in part, to many laws and judicial decisions, the 7
FY 2001 Budget Justification, U. S. Department of Agriculture, Forest
Service. 8 TVA v. Hill, 437 U. S. 153,185 (1978).

Congress has never explicitly accepted it as the Forest Service's highest
priority or acknowledged its effects on the availability of timber,
recreation, and other goods and services on the national forests. However,
in 1999, the Chairman of the Subcommittee on Forests and Public Land
Management, Senate Committee on Energy and Natural Resources, introduced S.
1320- the Public Lands Planning and Management Improvement Act of 1999. The
bill appears to establish a starting point for

the Congress and the administration to agree on the agency's mission
priorities. The bill's mission statement would make clear that the Forest
Service's overriding mission priority is ecosystem sustainability and
acknowledges the effects of sustaining ecosystems on the availability of
other uses on the national forests.

The Proposed The Government Performance and Results Act of 1993 (the Results
Act) Regulations Would Not

seeks to improve the effectiveness, efficiency, and accountability of
federal programs by establishing a system for agencies to set goals for
their Require That Forest programs' performance and to measure results.
Thus, the act provides a Plans Be Clearly

framework to translate the Forest Service's mission priorities into on-
theground Linked to Strategic

projects and activities. Goals, Objectives, and

The Forest Service has made some progress in identifying issues relating to
Strategies

ecological, economic, and social sustainability and in developing
statutorily required strategic goals and objectives as well as strategies to
achieve them. In particular, the agency is refining the goals and objectives
in its strategic plan and linking them to long- term performance measures
and 5- year milestones that better focus on outcomes and results to be
achieved over time. 9 In addition, the agency is developing strategies to
achieve some of the ecological goals and objectives in the strategic plan,
such as reducing the incidence of uncontrollable and often catastrophic
wildfires 10 and restoring degraded watersheds.

9 Draft USDA Forest Service Strategic Plan (2000 Revision), U. S. Department
of Agriculture, Forest Service (Nov. 1999). 10 Protecting People and
Sustaining Resources in Fire- Adapted Ecosystems: A Cohesive Strategy,
Forest Service (Apr. 13, 2000).

In testimony before the Subcommittee on Interior and Related Agencies, House
Committee on Appropriations, on February 16, 2000, the Chief of the Forest
Service said that the agency expects that “forest plan goals,
objectives, and performance measures will be aligned with the agency's
goals, objectives, and performance measures.” 11 However, the proposed
planning regulations do not require that forest plans be clearly linked to
the agency's strategic goals, objectives, and strategies. Instead, the
regulations state that officials should consider national- level, long- term
strategic goals and objectives, among other things, in managing the national
forests. The most substantive direction provided on how and where to
incorporate

national priorities into forest plans is found in the definition of
“resource management goal.” The proposed regulations would
require forest plans to include “general, non- quantitative”
resource management goals, which the regulations define as “statements
of intent” that link “laws, executive orders, regulations, and
applicable Forest Service strategic plans with specific measurable
objectives.” No further direction is given on how this should be done.
According to one Forest Service official involved in finalizing the agency's

proposed planning regulations, the proposed regulations are fully responsive
to the Chief's expectation that forest plans will be aligned with the
strategic plan. Conversely, officials within the Forest Service's
headquarters office responsible for the agency's strategic plan said they
believe that to comply with the requirements of the Results Act and the
Chief's expectation, the proposed regulations must be revised to require
that the goals and objectives of field units be linked to the agency's

strategic goals and objectives and that strategic goals and objectives drive
those of all other plans. 11 Managerial Accountability In the Forest
Service: A Review of the NAPA and GAO Reports on Accountability, Testimony
of Mike Dombeck, Chief, Forest Service, U. S. Department of Agriculture.

The approach taken by the Department of the Interior's National Park Service
suggests some positive insights for the Forest Service in linking plans to
results. The Park Service already requires the 376 separate units in the
National Park System to prepare local land management plans (similar in
function to forest plans) that address applicable servicewide goals as well
as goals specific to each unit's unique legislative and operating
environments. 12

The Proposed The Forest Service has long acknowledged the importance of
involving the

Regulations Would Not public and other government agencies throughout the
planning process and

basing decisions on sound information. However, the agency has often left
Hold the National implementation of these key elements of forest planning to
the discretion

Forests Accountable of its independent and autonomous forests. As a result,
these forests have

for Ensuring Effective sometimes (1) based their decisions on inaccurate or
incomplete data; (2)

not adequately involved the public and other government agencies Public
Participation, throughout their forest planning process; and (3) failed to
live up to Monitoring, and Data monitoring requirements, particularly those
for monitoring the effects of past planning decisions. These deficiencies
have driven up the cost and

Collection time to develop forest plans and driven down the agency's ability
to achieve planned objectives.

Building on the lessons learned, the Forest Service's 1995 proposed planning
regulations would have held the national forests more accountable for their
performance in developing and implementing forest plans by requiring them to
(1) develop strategies for involving the public and other government
agencies in their planning processes and for monitoring and evaluating their
management decisions and (2) make the strategies available to the public.
Similarly, we have recommended that the agency revise its proposed planning
regulations to require the national forests to develop strategies to gather
data on ecological, social, and economic issues that extend beyond their
administrative borders and to integrate these data into their forest
planning processes. However, the Forest Service's 1999 proposed planning
regulations do not require the forests to develop these strategies.
According to the preamble to the 1999 proposed regulations, the effort that
resulted in the 1999 proposed regulations was intended to have a perspective
independent of the earlier effort. Moreover, although the Forest Service
agrees that broad- scale,

12 National Park Service: Efforts to Link Resources to Results Suggest
Insights for Other Agencies (GAO/ AIMD- 98- 113, Apr. 10, 1998).

ecosystem- based assessments should be used in revising forest plans, it
does not think that a requirement to develop such a strategy should occur in
the rule itself. Instead, the Forest Service responded that it will include
requirements for gathering and integrating data into the forest planning
process into a system of manuals and handbooks that provide details to the
forests on how to implement the “spirit and intent” of the
planning regulations.

The 1995 Proposed Planning The agency's existing planning regulations
require the Forest Service to use

Regulations Would Have public participation activities early and often, as
applicable, throughout the

Held the Forests More planning process. Similarly, the 1999 proposed
planning regulations Accountable for Ensuring describe the importance of
public participation in the agency's decisionmaking

Effective Public and state that, in order to integrate the public into the
planning

process, the public should be provided with frequent and early Participation

opportunities to participate. Both the existing and the proposed planning
regulations give significant discretion to individual forest supervisors to
determine how and to what extent to involve the public in developing forest
plans. The 1995 proposed planning regulations would have also given forest
supervisors considerable discretion in determining how and to what extent to
involve the public in developing forest plans. However, the 1995 proposed
regulations would have also required forest supervisors to (1) develop
“communications strategies” describing how the public and other
governmental entities would participate in all stages of revising a forest
plan and (2) invite the public and others to express their ideas and
suggestions on the strategies. In addition, the 1995 proposed regulations
would have required forest supervisors to (1) meet with interested
representatives of other federal agencies and state, local, and tribal
governments to establish and document procedures for ongoing coordination
and communication throughout the plan revision process and

(2) document these procedures and make them available to the public.
Documenting public participation and interagency coordination strategies
establishes a basis for holding the supervisors more accountable for their
performance.

The 1995 Proposed Planning Under the agency's existing planning regulations,
forest plans must contain

Regulations Would Have provisions requiring periodic monitoring of the
plan's implementation to Held the Forests More assess how well the plan's
objectives have been met and how closely

Accountable for Monitoring management standards and guidelines have been
applied. Similarly, the

1999 proposed planning regulations acknowledge the importance of, and and
Evaluating Management

generally describe the purpose for, monitoring and evaluation. However,
Decisions

neither the existing nor the 1999 proposed planning regulations provide
sufficient guidance to ensure that monitoring and evaluation activities are
effective. In particular, the proposed regulations do not require forest
supervisors to (1) prioritize their monitoring and evaluation needs, (2)

describe procedures for implementing monitoring and evaluation activities,
or (3) identify needed changes to plans or plans' implementation.
Conversely, the 1995 proposed planning regulations would have required
forest supervisors to prepare a comprehensive monitoring and evaluation
strategy that would have, among other things, (1) provided instructions for
prioritizing monitoring and evaluation activities and for determining if
their results warrant changes to management decisions and (2) described the
procedures for implementing monitoring and evaluation activities. The 1995
proposed regulations would have also required forest supervisors to

make the strategies available to the public for review and comment at the
same time as the proposed forest plans. In addition, the 1995 proposed
regulations would have required forest supervisors to identify any needed
changes to plans or plans' implementation in annual monitoring and
evaluation reports.

Neither the 1995 nor the The agency's existing planning regulations require
forest supervisors to 1999 Proposed Planning obtain current inventory data
on forest resources. However, since the

Regulations Would Hold the agency adopted these regulations, its need for
gathering better and more Forests Adequately

comprehensive information on which to base decisions has increased. In
Accountable for Data

particular, in revising their plans, most, if not all, of the national
forests will need to address ecological, social, and economic issues that
extend beyond Collection and Use

their administrative boundaries and often extend onto other national
forests. In the early 1990s, the Forest Service began using ecosystem- based
assessments to address broad- scale ecological and socioeconomic issues.
Both the 1995 and the 1999 proposed planning regulations address some of the
lessons the agency has learned about conducting and using such assessments.
For instance, the 1999 proposed regulations state that (1) forest plans must
be based on the best available scientific information and analyses,
including information from a variety of geographic areas, some of

which can only be obtained, or can best be obtained, from broad- scale
assessments and (2) broad- scale assessments should be conducted at
appropriate geographic scales and reach conclusions.

However, neither the 1995 nor the 1999 proposed regulations adequately
reflect other lessons learned about conducting broad- scale, ecosystembased
assessments. For example, the 1999 proposed regulations (1) generally leave
decisions about whether to conduct assessments to the discretion of the
Forest Service's national forest supervisors, who have considerable autonomy
for interpreting and applying the agency's policies; (2) do not state when
in the process assessments should occur; (3) are silent on the need for
clear objectives and identifiable products; and (4) do

not require the regional offices and forests to identify their strategies
for involving the public.

Our February 2000 report on the Forest Service's planning process included
recommendations to better integrate broad- scale assessments into forest
planning. Specifically, we recommended that the 1999 proposed planning

regulations be revised to make clear that the regions and forests must use
broad- scale, ecosystem- based assessments in revising forest plans unless
they can justify their omission. We also recommended that the regulations be
revised to make clear that when a decision is made to conduct an assessment,
the region( s) and forests must prepare a strategy that identifies, among
other things, (1) how the assessment will be linked to the

forest plan's revision; (2) how the public and other governmental entities
will participate in the revision process; (3) what objectives the assessment
will meet and what products it will generate, including those of the highest

priority; and (4) how much the assessment will cost, how funding will be
secured for it, and what is likely to happen if full funding is not
available.

In responding to our recommendations, the Forest Service agreed with their
intent and desired outcome. However, rather than revise the 1999 proposed
planning regulations, the agency plans to place the necessary direction and
guidance in its system of directives that provide details to the forest on
how to implement the “spirit and intent” of the planning
revisions.

Conclusions By making clear that ecological sustainability- rather than
economic or social sustainability- is the Forest Service's highest mission
priority, the agency's proposed planning regulations, when finalized, would
provide the national forests with needed direction on how to resolve
conflicts among competing uses when developing and implementing forest
plans. However,

establishing ecological sustainability as the agency's highest mission
priority is better done outside procedural regulations governing forest
planning.

Other improvements to the Forest Service's planning process are best
addressed in the agency's planning regulations. These include the need to
(1) clearly link forest plans to the goals and objectives in the Forest
Service's statutorily required strategic plan as well as to the strategies
to achieve them and (2) develop strategies to involve the public and other
government agencies throughout the planning process and to base decisions on
sound information. However, the agency's 1999 proposed planning regulations
do not (1) clearly link forest plans to the strategic goals, objectives, and
strategies and (2) address some of the lessons learned on public
participation and monitoring that were identified during the development of,
and incorporated in, the 1995 proposed planning regulations. Since the
Forest Service plans to finalize the 1999 proposed planning regulations
early in October, 2000, it would be difficult for the agency to revise the
regulations to require the national forests to (1)

develop strategies for involving the public and other government agencies in
their planning processes and for monitoring and evaluating their management
decisions and (2) make the strategies available to the public. Therefore,
the Forest Service may need to place the necessary direction and guidance
relating to these key elements of forest planning in its system of
directives that provide details to the forests on how to implement the
planning regulations. However, because the national forests are primarily
responsible for implementing many of the strategic goals, objectives, and

strategies, the proposed planning regulations should be revised- even at
this late hour- to require that forest plans be clearly linked to the Forest
Service's strategic plan.

Recommendations to Although the Forest Service's 1999 proposed planning
regulations would

the Secretary of help national forests to resolve conflicts among competing
uses when developing and implementing forest plans by making clear that
ecological Agriculture

sustainability is the agency's highest priority, the Congress has never
explicitly accepted this as the Forest Service's highest priority.
Therefore, we recommend that the Secretary of Agriculture direct the Chief
of the Forest Service to work with the Congress to ensure agreement on what
the agency's mission priorities should be.

Moreover, since forest plans play a pivotal role in translating the agency's
strategic goals, objectives, and strategies into on- the- ground projects
and

activities, we also recommend that the Secretary of Agriculture direct the
Chief of the Forest Service to revise the agency's proposed planning
regulations to (1) require national forests to clearly link their forest
plans to the agency's strategic goals, objectives, and strategies and (2)
blend them with local priorities in revising the forest plans.

Finally, while we continue to believe that it would be preferable to place
the necessary direction and guidance relating to public participation and
monitoring in the Forest Service's planning regulations, we recommend that
the Secretary of Agriculture direct the Chief of the Forest Service to, at a
minimum, revise the agency's system of directives to require the national

forests to develop (1) communications strategies describing how the public
and other governmental entities will participate in all stages of revising a
forest plan and (2) comprehensive monitoring and evaluation strategies
describing how implementation of the plan will be monitored to determine how
well their objectives and requirements have been met and how the data will
be used to make changes to management decisions. We also recommend that the
forests be required to (1) involve the public and other

interested parties in developing these strategies and (2) make the
strategies available to the public as a basis for holding the forests more
accountable for their performance.

Agency Comments and We provided a draft of this report to the Forest Service
for its review and

Our Evaluation comment. Although the Forest Service generally agreed with
the desired outcomes of our recommendations, it did not agree that our

recommendations are needed to accomplish the outcomes. For example, we both
believe that there should be a “direct link” between forest
plans and the agency's national- level, long- term strategic goals and
objectives. However, the Forest Service believes that requiring forest
supervisors to

“consider” the strategic goals and objectives in managing the
national forests is adequate to ensure this link is established. Similarly,
we share Forest Service's view that the forest supervisors should (1) base
their decisions on accurate and complete data; (2) adequately involve the
public and other government agencies throughout the forest planning process;
and (3) live up to monitoring requirements. However, we also believe that
forest supervisors should be required to develop strategies to ensure these

key elements are integrated into the forest planning process. Finally, the
Forest Service believes that ecological sustainability must be its highest
priority. However, neither ecological sustainability nor the priority that
the agency assigns to it is specifically required by any law, and until the
Congress and the agency reach agreement on ecological sustainability as

the Forest Service's highest priority, holding the agency accountable for
its performance will be difficult. The Forest Service's comments and our
responses appear in appendix I.

We conducted our work between March 2000 and August 2000 in accordance with
generally accepted government auditing standards. Appendix II contains the
details of our scope and methodology.

We are sending copies of this report to Chairman Frank Murkowski, Senate
Committee on Energy and Natural Resources; Senator Jeff Bingaman, Ranking
Minority Member, Senate Committee on Energy and Natural Resources; Senator
Ron Wyden, Ranking Minority Member, Subcommittee on Forests and Public Land
Management, Senate Committee on Energy and Natural Resources; Chairman Don
Young, House Committee on Resources; Representative George Miller, Ranking
Minority Member, House Committee on Resources; Representative Adam Smith,
Ranking Minority Member, Subcommittee on Forests and Forest Health, House
Committee on Resources; the Honorable Dan Glickman, Secretary of
Agriculture; and the Honorable Mike Dombeck, Chief of the Forest Service. We
will also make copies available to others on request.

If you have any questions about this report, please contact me at (202) 512-
3841. Key contributors to this assignment were Charles S. Cotton, Charles T.
Egan, Kathy Hale, and Richard P. Johnson.

Barry T. Hill Associate Director, Energy, Resources, and Science Issues

Appendi xes Comments From the Forest Service and

Appendi x I

GAO's Response Note: GAO comments supplementing those in the report text
appear at the end of this appendix.

See comment 1. See comment 2.

See comment 3. See comment 4.

See comment 5.

The following are GAO's comments on the Forest Service's letter dated
September 25, 2000. GAO Comments 1. According to the Forest Service,
“ecological sustainability is not only a complement to multiple- use
and sustained yield management, but it is absolutely necessary for its
achievement.” However, the priority assigned

to ecological sustainability by the agency is not driven by the statutory
authorities specific to the management of the national forests, but rather,
is predicated on the general requirements in environmental laws. Further,
the

Congress has never explicitly accepted ecosystem sustainability as the
Forest Service's highest priority or acknowledged its effects on the
availability of timber, recreation, and other goods and services on the

national forests. Because the priority the Forest Service places on
sustaining ecosystems is both controversial and fundamental to the
management of national forests, we believe that explicit agreement with the
Congress on this subject is warranted and recommend that the Secretary of
Agriculture work to obtain such agreement.

2. According to the Forest Service, section 219.3( b) of the proposed
regulations provides that there be a “direct link” between
forest plans and national strategic goals and objectives in the new planning
process. However, the section merely requires that long- term strategic
goals, objectives, and outcome measures be “considered” in
managing the

national forests, not that they be clearly linked to the agency's strategic
plan.

3. We agree with the Forest Service that the agency's planning regulations
should (1) require that forest supervisors provide the public and others
opportunities to be involved early and often throughout the planning process
and (2) grant forest supervisors discretion to tailor public participation
to their specific planning efforts. Both the existing and 1999 proposed
regulations do this. However, under the exiting regulations, some forests
did not always adequately involve the public and others in the

planning process and the 1999 proposed regulations are not significantly
different. We believe the solution is to hold the forest supervisors
accountable for their actions. Our recommendation- based on the Forest

Service's 1995 proposed regulations- would establish a basis for holding the
supervisors more accountable for their performance by requiring national
forests to develop, document, and make available a communications strategy
for involving the public and others in the forest planning process. GAO
disagrees with the Forest Service that a

communications strategy could preclude tailoring public involvement
approaches to the specific planing effort. Forest Supervisors would continue
to have considerable discretion in determining how and to what extent to
involve the public in developing forest plans. Additionally, we recommend
that the public and other interested parties be involved in developing these
strategies, which could result in public involvement

approaches more finely tailored to specific planning efforts. 4. We agree
with the Forest Service about the importance of (1) monitoring and
evaluating management decisions and (2) prioritizing monitoring activities.
However, to ensure that monitoring and evaluation activities are effective,
we believe the agency's planning regulations must do more to hold
supervisors accountable for their actions than require an annual monitoring
and evaluation report. The annual monitoring and evaluation report that
would be required by the 1999 proposed regulations is a step in

the right direction, however, it does not focus on future monitoring and
evaluation activities. For this reason, we recommend that national forests
develop monitoring and evaluation strategies, similar to the communications
strategies we have also recommended, that would describe, among other
things, procedures for implementing monitoring and evaluation activities and
how the data will be used to make changes to management decisions. Like the
communications strategies, the public and

others should be involved in developing monitoring and evaluation strategies
and these strategies should be made available to the public as a basis for
holding the forests more accountable for their performance. 5. We agree with
the Forest Service that the amount and level of data collection and
synthesis should vary with the issues to be addressed in

revising a forest plan. However, as stated in our report, in revising forest
plans, most, if not all, of the national forests will need to address
ecological, social, and economic issues that extend beyond their
administrative boundaries. For these reasons, we recommended in our February
2000 report that broad scale, ecosystem based assessments be

used in revising forest plans unless their omission can be justified.
Further, to ensure that broad scale assessments are used effectively, we
also recommended in our February 2000 report that the forests prepare a
strategy that identifies, among other things, the products the assessment
will generate, their priority and cost, and how they will be used in
revising forest plans. This is a prudent measure to ensure that, when
assessments are appropriate, they are integrated effectively into forest
planning. We believe these recommendations are consistent with a flexible
process that yields the data appropriate to address an issue and do not
mandate one

approach that may provide too much or too little information to address the
issue at hand.

Appendi x II

Objectives, Scope, and Methodology Over the last 6 years, we have issued
over 2 dozen products that have identified deficiencies in the Forest
Service's planning process and included recommendations to improve the cost-
effectiveness and timeliness of this process. Concerned about the outcome of
the required forest plan revisions, the Chairman of the Subcommittee on
Forests and Public Land Management, Senate Committee on Energy and Natural
Resources, and the Chairman of the Subcommittee on Forests and Forest

Health, House Committee on Resources, asked us to provide our observations
on the extent to which the Forest Service's proposed planning regulations
address these deficiencies and recommendations.

Our analysis of our prior products identified the need to (1) make clear the
agency's mission priorities before beginning the process to revise a forest
plan; (2) link forest plans to agencywide goals, objectives, and strategies;

and (3) hold the forests more accountable for key elements of forest
planning. We then reviewed the agency's 1999 proposed planning regulations
to determine how they addressed each of the three themes. In addition, we
met with Forest Service officials from the office of the Deputy Chief,
Programs and Legislation, responsible for developing the agency's strategic
plan and with officials from the office of the Deputy Chief, National Forest
System, responsible for drafting the proposed regulations.

We conducted our work between March 2000 and August 2000 in accordance with
generally accepted government auditing standards.

Chapt er 1

Related GAO Products Fire Management: Lessons Learned From the Cerro Grande
(Los Alamos) Fire (GAO/ T- RCED- 00- 257, July 27, 2000). Forest Service:
Actions Needed for the Agency to Become More Accountable for Its Performance
(GAO/ T- RCED- 00- 236, June 29, 2000). Tongass National Forest: Process
Used to Modify the Forest Plan (GAO/ RCED- 00- 45, Apr. 17, 2000).

Forest Service: Broad- Scale Assessments Could Be Better Integrated Into the
Forest Planning Process (GAO/ T- RCED- 00- 146, Apr. 11, 2000). Forest
Service: Status of Efforts to Improve Accountability (GAO/ TRCED/ AIMD- 00-
93, Feb. 16, 2000).

Forest Service Planning: Better Integration of Broad- Scale Assessments Into
Forest Plans Is Needed (GAO/ RCED- 00- 56, Feb. 15, 2000).

Forest Service: A Framework for Improving Accountability (GAO/ RCED/ AIMD-
00- 2, Oct. 13, 1999). Federal Land Management: Comments on Selected
Provisions of S. 1320-- A Bill to Revise Federal Land Management Planning
(GAO/ T- RCED- 99- 270, July 22, 1999).

Western National Forests: Status of Forest Service's Efforts to Reduce
Catastrophic Wildfire Threats (GAO/ T- RCED- 99- 241, June 29, 1999).

Forest Service Priorities: Evolving Mission Favors Resource Protection Over
Production (GAO/ RCED- 99- 166, June 17, 1999). Ecosystem Planning:
Northwest Forest and Interior Columbia River Basin Plans Demonstrate
Improvements in Land- Use Planning (GAO/ RCED- 9964, May 26, 1999).

Western National Forests: A Cohesive Strategy is Needed to Address
Catastrophic Wildfire Threats (GAO/ RCED- 99- 65, Apr. 2, 1999).

Forest Service: Barriers to and Opportunities for Generating Revenue (GAO/
T- RCED- 99- 81, Feb. 10, 1999).

Western National Forests: Nearby Communities Are Increasingly Threatened by
Catastrophic Wildfires (GAO/ T- RCED- 99- 79, Feb. 9, 1999).

Forest Service Management: Little Has Changed as a Result of the Fiscal Year
1995 Budget Reforms (GAO/ RCED- 99- 2, Dec. 2, 1998). Western National
Forests: Catastrophic Wildfires Threaten Resources and Communities (GAO/ T-
RCED- 98- 273, Sept. 28, 1998).

Oregon Watersheds: Many Activities Contribute to Increased Turbidity During
Large Storms (GAO/ RCED- 98- 220, July 29, 1998). Forest Service: Lack of
Financial and Performance Accountability Has Resulted in Inefficiency and
Waste (GAO/ T- RCED/ AIMD- 98- 135, Mar. 26, 1998). Forest Service: Barriers
to Generating Revenue or Reducing Costs (GAO/ RCED- 98- 58, Feb. 13, 1998).

The Results Act: Observations on the Forest Service's May 1997 Draft Plan
(GAO/ T- RCED- 97- 223, July 31, 1997). Forest Service Decision- Making: A
Framework for Improving Performance (GAO/ RCED- 97- 71, Apr. 29, 1997).
Tongass National Forest: Lack of Accountability for Time and Costs Has
Delayed Forest Plan Revision (GAO/ T- RCED- 97- 153, Apr. 29, 1997).

Forest Service Decision- Making: Greater Clarity Needed on Mission
Priorities (GAO/ T- RCED- 97- 81, Feb. 25, 1997).

Federal Land Management: Streamlining and Reorganization Issues (GAO/ T-
RCED- 96- 209, June 27, 1996). Forest Service: Issues Related to Managing
National Forests for Multiple Uses (GAO/ T- RCED- 96- 111, Mar. 26, 1996).

Forest Service: Issues Relating to Its Decisionmaking Process (GAO/ TRCED-
96- 66, Jan. 25, 1996).

Ecosystem Management: Additional Actions Needed to Adequately Test a
Promising Approach (GAO/ RCED- 94- 111, Aug. 16, 1994).

(141418) Lett er

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Appendix I Comments From the Forest Service and GAO's Response

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Appendix I Comments From the Forest Service and GAO's Response

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Appendix II

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Chapter 1

Chapter 1 Related GAO Products

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