    Forest Service Decision-Making: A Framework for Improving Performance
    (Chapter Report, 04/29/97, GAO/RCED-97-71).

    Pursuant to congressional requests, GAO reviewed the Forest Service's
    decisionmaking process, focusing on: (1) the inadequate attention that
    the Forest Service has given to improving the process; (2) the lack of
    agreement, both inside and outside the agency, on how it is to resolve
    conflicts among competing uses on its lands; (3) unresolved interagency
    issues that transcend its administrative boundaries and jurisdiction;
    and (4) differences in the requirements of laws that help frame its
    decisionmaking.

    GAO noted that: (1) some of the inefficiency in developing forest plans
    and reaching project-level decisions, as well as the ineffectiveness in
    achieving the plans' objectives, has occurred because the Forest Service
    has not given adequate attention to improving its decisionmaking
    process, including improving accountability for its performance; (2) as
    a result, the Forest Service: (a) must request more funds to accomplish
    fewer objectives during the yearly budget and appropriation process; and
    (b) has not corrected long-standing deficiencies within its
    decisionmaking process that have contributed to increased costs and time
    and/or the inability to achieve planned objectives; (3) strengthening
    accountability for performance within the Forest Service and improving
    the efficiency and effectiveness of its decisionmaking is contingent on
    establishing long-term strategic goals that are based on clearly defined
    mission priorities; (4) however, agreement does not exist on the
    agency's long-term strategic goals; (5) this lack of agreement is the
    result of a more fundamental disagreement, both inside and outside the
    Forest Service, over which uses the agency is to emphasize under its
    broad multiple-use and sustained-yield mandate and how best to ensure
    the long-term sustainability of these uses; (6) issues that transcend
    the agency's administrative boundaries and jurisdiction also affect the
    efficiency and effectiveness of the agency's decisionmaking; (7) in
    particular, the Forest Service has had difficulty reconciling the
    administrative boundaries of the national forests with the boundaries of
    natural systems, such as watersheds and vegetative and animal
    communities, both in planning and in assessing the effects of federal
    and nonfederal activities on the environment; (8) finally, the
    requirements of planning and environmental laws, enacted primarily
    during the 1960s and 1970s, have not been harmonized; (9) differences
    among the requirements of various laws and their differing judicial
    interpretations require some issues to be analyzed or reanalyzed at
    different stages in the Forest Service's decisionmaking process without
    any clear sequence leading to their timely resolution; (10) additional
    differences among the statutorily required approaches for protecting
    various resources have also sometimes been difficult to reconcile; and
    (11) however, GAO believes that statutory changes to improve the effici*

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

     REPORTNUM:  RCED-97-71
         TITLE:  Forest Service Decision-Making: A Framework for Improving
                 Performance
          DATE:  04/29/97
       SUBJECT:  Land management
                 National forests
                 Agency missions
                 Strategic planning
                 Environmental law
                 Land use law
                 Forest management
                 Accountability
                 Interagency relations
                 Wildlife conservation
    IDENTIFIER:  Forest Service Timber Sales Program
                 Black Hills National Forest (SD)
                 Carson National Forest (NM)
                 Eldorado National Forest (CA)
                 Flathead National Forest (MT)
                 Deschutes National Forest (OR)
                 Mt. Hood National Forest (OR)
                 Gifford Pinchot National Forest (WA)
                 Ouachita National Forest (AR)
                 Chattahoochee-Oconee National Forest (GA)
                 Nantahala-Pisgah National Forest (NC)
                 Forest Service Emergency Salvage Timber Sale Program
                 Wenatchee National Forest (WA)
                 Knutson-Vandenberg Trust Fund
                 Salvage Sale Fund
                 Columbia River Basin (WA)
                 Boise National Forest (ID)

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    Cover
    ================================================================ COVER

    Report to Congressional Requesters

    April 1997

    FOREST SERVICE DECISION-MAKING - A
    FRAMEWORK FOR IMPROVING
    PERFORMANCE

    GAO/RCED-97-71

    Forest Service Decision-Making

    (140541)

    Abbreviations
    =============================================================== ABBREV

      CEQ - Council on Environmental Quality
      EA - environmental assessment
      EIS - environmental impact statement
      EPA - Environmental Protection Agency
      ESA - Endangered Species Act
      FACA - Federal Advisory Committee Act
      FWS - Fish and Wildlife Service
      FWS/NMFS -
      GAO - General Accounting Office
      GIS - geographic information system
      GPRA - Government Performance and Results Act
      NEPA - National Environmental Policy Act
      NFMA - National Forest Management Act
      NMFS - National Marine Fisheries Service
      OTA - Office of Technology Assessment
      RPA - Forest and Rangeland Renewable Resources Planning Act

    Letter
    =============================================================== LETTER

    B-276170

    April 29, 1997

    Congressional Requesters

    As agreed with your offices, this report discusses the underlying
    causes of inefficiency and ineffectiveness in the decision-making
    process used by the Department of Agriculture's Forest Service in
    carrying out its mission.  The report contains a matter for
    congressional consideration and recommendations to the Chair of the
    Council on Environmental Quality and to the Secretary of Agriculture
    designed to reduce the costs and time of the decision-making process
    and/or improve the agency's ability to deliver what is expected or
    promised.

    We are sending copies of this report to the appropriate congressional
    committees, the Chair of the Council on Environmental Quality, the
    Secretary of Agriculture, and the Chief of the Forest Service.  We
    will also make copies available to others upon request.

    Please call me on (202) 512-3841 if you or your staff have any
    questions about this report.  Major contributors to this report are
    listed in appendix VI.

    Victor S.  Rezendes
    Director, Energy, Resources,
     and Science Issues

    List of Requesters

    The Honorable Frank H.  Murkowski
    Chairman, Committee on Energy
     and Natural Resources
    United States Senate

    The Honorable Larry Craig
    Chairman, Subcommittee on Forests
     and Public Land Management
    Committee on Energy and
     Natural Resources
    United States Senate

    The Honorable James V.  Hansen
    Chairman, Subcommittee on National Parks
     and Public Lands
    Committee on Resources
    House of Representatives

    The Honorable Ralph Regula
    Chairman, Subcommittee on Interior
     and Related Agencies
    Committee on Appropriations
    House of Representatives

    The Honorable Conrad Burns
    United States Senate

    EXECUTIVE SUMMARY
    ============================================================ Chapter 0

       PURPOSE
    ---------------------------------------------------------- Chapter 0:1

    The decision-making process used by the Department of Agriculture's
    Forest Service in carrying out its mission is costly and
    time-consuming, and the agency often fails to achieve its planned
    objectives.  The agency has spent over 20 years and over $250 million
    developing multiyear plans for managing national forests.  It also
    spends about $250 million a year for environmental studies to support
    individual projects.  However, according to an internal Forest
    Service report, inefficiencies within this process cost up to $100
    million a year at the project level alone.  In addition, by the time
    the agency has completed its decision-making, it often finds that it
    is unable to achieve the plans' objectives or implement planned
    projects because of new information and events, as well as changes in
    funding and natural conditions.

    In response to congressional requests, GAO examined the Forest
    Service's decision-making process.  In this report, GAO discusses the
    internal and external causes of inefficiency and ineffectiveness in
    the process:  (1) the inadequate attention that the Forest Service
    has given to improving the process; (2) the lack of agreement, both
    inside and outside the agency, on how it is to resolve conflicts
    among competing uses on its lands; (3) unresolved interagency issues
    that transcend its administrative boundaries and jurisdiction; and
    (4) differences in the requirements of laws that help frame its
    decision-making.

       BACKGROUND
    ---------------------------------------------------------- Chapter 0:2

    The Forest Service manages about 192 million acres of land--nearly 9
    percent of the nation's total surface area and about 30 percent of
    all federal lands.  Laws guiding the management of the nation's 155
    national forests require the agency to manage its lands under the
    principles of multiple use and sustained yield to meet the diverse
    needs of the American people.

    Under the multiple-use principle, the Forest Service is required to
    plan for six renewable surface uses--outdoor recreation, rangeland,
    timber, watersheds and water flows, wilderness, and wildlife and
    fish.  Under the sustained-yield principle, the agency is to manage
    its lands to provide high levels of all of these uses to current
    users while sustaining undiminished the lands' ability to produce
    these uses for future generations.

    To carry out its mission, the Forest Service follows a
    decision-making process that includes (1) preparing a long-term
    strategic plan that maps the agency's course for the next decade and
    beyond, (2) developing regional guides that direct the management of
    its national forests, (3) developing plans for managing each forest,
    and (4) reaching project-level decisions for implementing these
    plans.  In developing plans and reaching project-level decisions, the
    Forest Service must comply with the requirements of environmental
    statutes, including the National Environmental Policy Act, the
    Endangered Species Act, the Clean Water Act, and the Clean Air Act.
    The Council on Environmental Quality in the Executive Office of the
    President is responsible for issuing governmentwide regulations to
    implement the provisions of the National Environmental Policy Act.
    The responsibility for implementing and enforcing environmental laws
    and regulations is dispersed among several federal regulatory
    agencies, as well as state and local agencies.

       RESULTS IN BRIEF
    ---------------------------------------------------------- Chapter 0:3

    Some of the inefficiency in developing forest plans and reaching
    project-level decisions, as well as the ineffectiveness in achieving
    the plans' objectives, has occurred because the Forest Service has
    not given adequate attention to improving its decision-making
    process, including improving accountability for its performance.  As
    a result, the Forest Service (1) must request more funds to
    accomplish fewer objectives during the yearly budget and
    appropriation process and (2) has not corrected long-standing
    deficiencies within its decision-making process that have contributed
    to increased costs and time and/or the inability to achieve planned
    objectives.

    Strengthening accountability for performance within the Forest
    Service and improving the efficiency and effectiveness of its
    decision-making is contingent on establishing long-term strategic
    goals that are based on clearly defined mission priorities.  However,
    agreement does not exist on the agency's long-term strategic goals.
    This lack of agreement is the result of a more fundamental
    disagreement, both inside and outside the Forest Service, over which
    uses the agency is to emphasize under its broad multiple-use and
    sustained-yield mandate and how best to ensure the long-term
    sustainability of these uses.

    Issues that transcend the agency's administrative boundaries and
    jurisdiction also affect the efficiency and effectiveness of the
    agency's decision-making.  In particular, the Forest Service has had
    difficulty reconciling the administrative boundaries of the national
    forests with the boundaries of natural systems, such as watersheds
    and vegetative and animal communities, both in planning and in
    assessing the effects of federal and nonfederal activities on the
    environment.

    Finally, the requirements of planning and environmental laws, enacted
    primarily during the 1960s and 1970s, have not been harmonized.
    Differences among the requirements of various laws and their
    differing judicial interpretations require some issues to be analyzed
    or reanalyzed at different stages in the Forest Service's
    decision-making process without any clear sequence leading to their
    timely resolution.  Additional differences among the statutorily
    required approaches for protecting various resources--such as
    endangered and threatened species, water, air, diverse plant and
    animal communities, and wilderness--have also sometimes been
    difficult to reconcile.  However, GAO believes that statutory changes
    to improve the efficiency and effectiveness of the Forest Service's
    decision-making process cannot be identified until agreement is first
    reached on the agency's mission priorities.

       PRINCIPAL FINDINGS
    ---------------------------------------------------------- Chapter 0:4

          THE FOREST SERVICE HAS NOT
          GIVEN ADEQUATE ATTENTION TO
          IMPROVING ITS
          DECISION-MAKING PROCESS
    -------------------------------------------------------- Chapter 0:4.1

    The Forest Service has not given adequate attention to reducing the
    costs and time of its decision-making and improving its ability to
    deliver what is expected or promised.  As a result, the Forest
    Service must request more annual appropriations to achieve fewer
    planning objectives, and deficiencies within the decision-making
    process that have been known to the agency for a decade or more have
    not been corrected.

    The Forest Service has made little progress in holding its managers
    accountable for their performance.  For example, in response to
    congressional concerns about the Forest Service's inability to
    deliver what is expected or promised, the Chief, in the fall of 1991,
    formed a task force of employees from throughout the agency to review
    the issue of accountability.  The task force's February 1994 report
    set forth a seven-step process to strengthen accountability.  Steps
    in the process included (1) establishing work agreements that include
    measures and standards with customers' involvement, (2) assessing
    performance, and (3) communicating results to customers.  However,
    the task force's recommendations were never implemented.  Rather,
    they were identified as actions that the agency planned to implement
    over the next decade.

    Because the Forest Service has made little progress in holding
    managers accountable for their performance, it must request more
    funds to accomplish fewer objectives in forest plans during the
    yearly budget and appropriation process.  For example, in fiscal year
    1991, the Congress asked the Forest Service to develop a multiyear
    program to reduce the costs of its timber program by not less than 5
    percent per year.  The Forest Service responded to these and other
    concerns by undertaking two major examinations of its timber program
    and is now preparing to undertake a third.  However, with no
    incentive to act, the agency has not implemented any of the
    recommended improvements agencywide.  In the interim, the costs
    associated with preparing and administering timber sales have
    continued to rise.  As a result, for fiscal year 1998, the agency is
    requesting $12 million (6 percent) more for timber sale management
    than was appropriated for fiscal year 1997 while proposing to offer
    0.4 billion board feet (10 percent) less timber for sale.

    Another result of the lack of accountability within the Forest
    Service has been that long-standing deficiencies within the agency's
    decision-making process, which have driven up costs and time and/or
    driven down the ability to achieve planned objectives, have not been
    corrected.  These deficiencies include (1) not adequately monitoring
    the effects of past management decisions to more accurately estimate
    the effects of similar future decisions and to modify decisions when
    new information is uncovered or when preexisting monitoring
    thresholds are crossed, (2) not maintaining comparable environmental
    and socioeconomic data that are useful and easily accessible to
    forest managers, and (3) not adequately involving the public at the
    beginning of the decision-making process when problems are
    identified, data are gathered, and relationships are established and
    maintaining their involvement throughout the process.

    For example, adequate monitoring of the effects of past management
    decisions is critical to accurately estimate the environmental
    effects of similar future decisions.  Moreover, monitoring can be
    used as an effective tool when the effects of a decision may be
    difficult to determine in advance because of uncertainty or costs.
    However, the Forest Service (1) has historically given low priority
    to monitoring during the annual competition for scarce resources, (2)
    continues to approve projects without an adequate monitoring
    component, and (3) generally does not monitor the implementation of
    its plans as its regulations require.  The Forest Service's past
    failure to monitor represents a lost opportunity to reduce the costs
    and time of future decision-making.

          AGREEMENT NEEDS TO BE
          REACHED ON HOW THE FOREST
          SERVICE SHOULD RESOLVE
          CONFLICTS AMONG COMPETING
          USES
    -------------------------------------------------------- Chapter 0:4.2

    The Government Performance and Results Act of 1993 is designed to
    hold federal agencies more accountable for their performance by
    requiring them to establish performance goals, measures, and reports
    that provide a system of accountability for results.  It requires
    each federal agency to develop, no later than September 30, 1997, a
    strategic plan that covers a period of at least 5 years.  The Forest
    Service is planning to prepare two long-term strategic plans--one to
    comply with the requirements of the Government Performance and
    Results Act and another that maps the agency's course for the next
    decade and beyond, as required by another statute.

    Successful implementation of the requirements of the Government
    Performance and Results Act is contingent on establishing long-term
    strategic goals that are based on clearly defined mission priorities.
    However, agreement does not exist on the Forest Service's long-term
    strategic goals.  This lack of agreement is the result of a more
    fundamental disagreement, both inside and outside the Forest Service,
    over which uses to emphasize under the agency's broad multiple-use
    and sustained-yield mandate and how best to ensure the long-term
    sustainability of these uses.

    During the last 10 years, the Forest Service has increasingly shifted
    the emphasis under its broad multiple-use and sustained-yield mandate
    from consumption (primarily producing timber) to conservation
    (primarily sustaining wildlife and fish).  This shift is taking place
    in reaction to requirements in planning and environmental laws and
    their judicial interpretations--reflecting changing public values and
    concerns--together with social, ecological, and other factors.  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 current primary missions of the Forest
    Service and other federal agencies.  When proposing a project, the
    Forest Service bears the burden of demonstrating that its actions
    will not likely jeopardize listed species.

    The increasing emphasis on sustaining wildlife and fish conflicts
    with the older emphasis on producing timber and underlies the Forest
    Service's inability to achieve the goals and objectives for timber
    production set forth in many of the first forest plans.  In addition,
    this attention to sustaining wildlife and fish will likely constrain
    future uses of the national forests, such as recreation.  The demand
    for recreation is expected to grow and may increasingly conflict with
    both sustaining wildlife and fish and producing timber on Forest
    Service lands.

    While the agency continues to reduce its emphasis on consumption and
    increase its emphasis on conservation, the Congress has never
    explicitly accepted this shift in emphasis or acknowledged its
    effects on the availability of other uses on national forests.  If
    the Forest Service is to be held accountable for its performance, the
    agency will need to consult with the Congress on its strategic
    long-term goals, as the Government Performance and Results Act
    requires.  This process may entail identifying legislative changes
    that are needed to clarify or modify the Congress's intent and
    expectations.

    Such a consultation would create an opportunity for the Forest
    Service to gain a clearer understanding of which uses to emphasize
    under its broad multiple-use and sustained-yield mandate and how to
    resolve conflicts or make choices among competing uses on its lands.
    This understanding would, in turn, provide the agency with a basis
    for establishing long-term strategic goals, as well as performance
    goals and measures that are linked to them.

          INTERAGENCY ISSUES AFFECT
          THE FOREST SERVICE'S
          DECISION-MAKING
    -------------------------------------------------------- Chapter 0:4.3

    Issues that transcend the agency's administrative boundaries and
    jurisdiction also adversely affect the efficiency and effectiveness
    of the Forest Service's decision-making process.  These issues
    include differences in the geographic areas that must be considered
    in reaching decisions under different planning and environmental
    laws.

    The Forest Service and other federal land management agencies are
    authorized to plan primarily along administrative boundaries, such as
    those defining national forests and parks.  Conversely, environmental
    statutes and regulations require the agencies to analyze
    environmental issues and concerns along the boundaries of natural
    systems, such as watersheds and vegetative and animal communities.
    For example, regulations implementing the National Environmental
    Policy Act require the agencies to assess the effects of their
    actions on natural systems.

    Because the boundaries of administrative units and natural systems
    are frequently different, federal land management plans have often
    considered effects only on portions of natural systems or portions of
    the habitats of wide-ranging species, such as migratory birds, bears,
    and anadromous fish (including salmon).  For example, the Interior
    Columbia River Basin, a recognized ecological system, contains 74
    separate federal land units, including 35 national forests, each with
    its own management plan and information database.  Not analyzing
    effects on natural systems and their components at the appropriate
    ecological scale can result in duplicative environmental analyses for
    individual plans and projects, increasing the costs and time required
    for analysis and reducing the effectiveness of federal land
    management decision-making.

    Over the past few years, several major studies have examined the need
    to reconcile differences in the geographic areas that federal
    agencies must consider when reaching decisions.  Among the options
    for reconciliation that have been suggested are changes to the
    Council on Environmental Quality's regulations and guidance for
    implementing the National Environmental Policy Act.  Such changes
    include amending the Council's regulations to require that the
    environmental analysis accompanying a plan or project be "tiered," or
    linked, to a broader-scoped environmental study and that the analysis
    itself focus on the environmental issues specific to the plan or
    project.  While tiering is currently allowed, it is not required.

    According to Council officials, changes to the act's regulations and
    guidance are not being considered at this time.  Instead, the Council
    plans to rely primarily on interagency agreements.  However,
    interagency agreements (1) have not been lived up to by agencies in
    the past, (2) are generally not enforceable by outside parties, and
    (3) do not provide a basis for common approaches among all agencies.
    Also, federal land management and regulatory agencies sometimes do
    not work efficiently and effectively together to address issues that
    transcend their boundaries and jurisdictions.  In addition, the
    environmental and socioeconomic data gathered by federal agencies are
    often not comparable, large gaps in the information exist, and
    federal agencies lack awareness of who has what information.
    Therefore, although strong leadership by the Council would help to
    ensure that interagency agreements accomplish their intended
    objectives, the Council may also need to consider changes to its
    regulations and guidance for implementing the National Environmental
    Policy Act.

          DIFFERENCES IN THE
          REQUIREMENTS OF LAWS AFFECT
          THE FOREST SERVICE'S
          DECISION-MAKING
    -------------------------------------------------------- Chapter 0:4.4

    Finally, differences in the requirements of numerous planning and
    environmental laws, enacted primarily during the 1960s and 1970s,
    produce inefficiency and ineffectiveness in the Forest Service's
    decision-making.  Requirements to consider new information and events
    and differing judicial interpretations of the same statutory
    requirements have made it difficult for the Forest Service and other
    federal agencies to predict when any given decision can be considered
    final and can be implemented, increasing the costs and time of
    decision-making and reducing the agencies' ability to achieve the
    objectives in their plans.

    For instance, the listing of a species as endangered or threatened
    under the Endangered Species Act after a forest plan has been
    approved can require the Forest Service to reinitiate formal
    consultations with federal regulatory agencies to amend or revise the
    plan.  The listing may also prohibit the Forest Service from
    implementing projects under the plans that may affect the species
    until the new round of consultations has been completed.  Recent
    federal court decisions have required the Forest Service to
    reinitiate consultations on several approved forest plans.  For
    example, after a species of salmon in the Pacific Northwest and a
    species of owl in the Southwest were listed as threatened under the
    Endangered Species Act, the courts ruled that the agency could not
    implement projects under the plans that might affect the species
    until the new rounds of consultations had been completed.

    Differing judicial interpretations of the same statutory requirements
    have also established conflicting requirements.  For instance, three
    federal circuit courts of appeals have held that the approval of a
    forest plan represents a decision that can be judicially challenged
    and prohibited from being implemented.  Conversely, two other federal
    circuit courts of appeals have held that a forest plan does not
    represent a decision and that only a project can be judicially
    challenged, at which time the adequacy of the plan's treatment of
    larger-scale environmental issues arising in the project can be
    reconsidered.

    In addition, differences between environmental laws and agencies'
    planning statutes can be difficult to reconcile.  Whereas
    environmental laws typically address individual resources--such as
    endangered and threatened species, water, and air--the Forest
    Service's and other federal land management agencies' planning
    statutes generally establish objectives for multiple resources--such
    as sustaining diverse plant and animal communities, securing
    favorable water flow conditions, and preserving wilderness.  These
    different approaches to achieving similar environmental objectives
    have sometimes been difficult for the Forest Service and other
    federal agencies to reconcile, at least in the short term.  For
    example, prescribed burning to restore the forests' health and to
    sustain diverse plant and animal communities may be appropriate under
    the Forest Service's planning statutes but may be difficult to
    reconcile in the short term with air and water quality standards
    under the Clean Air and Clean Water acts.

    Adequately addressing the differences in the requirements of laws
    affecting the Forest Service's decision-making would require a
    systematic and comprehensive analysis of the laws to avoid making
    changes that would entail unintended consequences for the future.
    GAO has observed that the Forest Service's decision-making process is
    clearly broken and in need of repair.  Moreover, to improve the
    efficiency and effectiveness of the process, a consensus for
    statutory changes appears to be growing.  However, any legislation
    that may be needed to clarify or modify the Congress's intent and
    expectations requires that the Forest Service and the Congress reach
    agreement on the agency's long-term strategic goals, on the uses that
    the agency should emphasize under its broad multiple-use and
    sustained-yield mandate, and on the steps that the agency should take
    to resolve conflicts or make choices among competing uses on its
    lands.

    Without agreement on the Forest Service's mission priorities, GAO
    sees distrust and gridlock prevailing in any effort to streamline the
    agency's statutory framework.  For instance, during his Senate
    confirmation hearing in April 1995, the Secretary of Agriculture
    pledged to work with the Congress to identify statutory changes to
    improve the processes for implementing the Forest Service's mission.
    However, the Secretary has not sent to the Congress either his
    analysis or the options for changing the current statutory framework
    suggested by the Forest Service in 1995.  Administration officials
    have said that they are hesitant to suggest changes to the procedural
    requirements of planning and environmental laws because they believe
    that the Congress may also make substantive changes to the laws with
    which they would disagree.

       MATTER FOR CONGRESSIONAL
       CONSIDERATION
    ---------------------------------------------------------- Chapter 0:5

    The Congress may wish to consider how the requirements of the
    Government Performance and Results Act can be integrated most
    efficiently into the Forest Service's current decision-making
    process.  Specifically, the Congress may wish to consider eliminating
    the requirement in the Forest Service's statutory framework that the
    agency develop a strategic plan for the next decade or more when it
    is also required to develop a similar strategic plan under the
    Government Performance and Results Act.

       RECOMMENDATION TO THE SECRETARY
       OF AGRICULTURE
    ---------------------------------------------------------- Chapter 0:6

    GAO recommends that the Secretary of Agriculture direct the Chief of
    the Forest Service to identify how the agency will link a long-term
    strategic goal with annual performance goals and measures.

       RECOMMENDATIONS TO THE CHAIR OF
       THE COUNCIL ON ENVIRONMENTAL
       QUALITY
    ---------------------------------------------------------- Chapter 0:7

    GAO recommends that the Chair of the Council on Environmental Quality
    change the Council's regulations for implementing the National
    Environmental Policy Act to require, rather than merely allow,
    federal agencies to tier plans and projects to broader-scoped
    studies.  In addition, GAO recommends that the Chair revise the
    Council's regulations and guidance for implementing the act to
    improve interagency coordination; identify a baseline of comparable
    environmental data needed for agencies to implement the act; and
    assume or assign responsibility for collecting, managing, and making
    the data available to other users.  GAO is not recommending precise
    changes to the Council's regulations or guidance because GAO believes
    that such changes are better left for the Council to determine on the
    basis of its own internal study and its evaluation of the outside
    views solicited during its effort to reinvent federal agencies'
    implementation of the National Environmental Policy Act.

       AGENCY COMMENTS AND GAO'S
       EVALUATION
    ---------------------------------------------------------- Chapter 0:8

    GAO requested and received written comments on a draft of this report
    from the Forest Service and the Council on Environmental Quality.
    The Forest Service said that it agreed with many of the report's
    goals and identified actions that it is taking to clarify its
    long-term strategic goals, improve its accountability, and streamline
    its administrative processes and decision-making.  Similarly, the
    Council agreed with the goals for implementing the National
    Environmental Policy Act articulated in the report but said it was
    using different mechanisms to achieve these goals.

    The Forest Service said that it intends to establish strategic goals
    and related performance measures for managers, as well as work in
    partnership with other agencies more closely and issue revised
    regulations for implementing the National Forest Management Act.  GAO
    believes that implementing these actions would improve the efficiency
    and effectiveness of the agency's decision-making process.  However,
    as the report notes, while the Forest Service can and does identify
    problems, according to the agency's own analysis, without external
    attention it often fails to take corrective action.  In its comments,
    the agency did not discuss either a schedule to implement the
    improvements or a plan to closely monitor its progress and
    periodically report on its performance, both of which GAO believes
    are needed to break the cycle of studying and restudying issues
    without any accountability or clear sequence for resolving them.  The
    Forest Service did not comment on GAO's recommendation to the
    Secretary of Agriculture.

    The Council on Environmental Quality identified actions that it is
    taking to reinvent the implementation of the National Environmental
    Policy Act on an agency-by-agency as well as on a more generic basis.
    These actions include streamlining procedures at individual agencies
    and examining issues on a sector-by-sector basis (e.g., timber,
    grazing, and oil and gas).  GAO agrees with the Council that (1)
    differences among the cultures, organizations, and institutional
    goals of various federal agencies, as well as the substantive nature
    of their underlying missions, require the Council's regulations
    implementing the act to be generic in nature and (2) regulatory
    changes often need to be tailored specifically to individual
    agencies' processes.  However, as this report indicates, some
    decision-making issues transcend federal agencies' administrative
    boundaries and jurisdictions, and for some of these issues, changes
    in the Council's regulations and guidance need to be considered.  The
    Council did not agree with GAO's recommendation that it should change
    its guidance and regulations.  However, GAO's recommendation to the
    Council's Chair is intended to ensure that the Council's planned
    multiyear reinvention effort does not prematurely or arbitrarily
    close off options for implementing the act more efficiently and
    effectively.  GAO also clarified this recommendation to indicate that
    it is not recommending precise changes to the Council's regulations
    or guidance because, in its view, such changes can be best determined
    by the Council.  On the basis of the agencies' comments, GAO revised
    the draft report where appropriate.  The agencies' comments, together
    with GAO's responses to them, are presented fully in appendixes IV
    and V.

    INTRODUCTION
    ============================================================ Chapter 1

    In carrying out its mission, the Department of Agriculture's Forest
    Service follows a decision-making process that is largely based on
    planning laws enacted during the 1970s.  This process includes (1)
    preparing a long-term strategic plan that maps the agency's course
    for the next decade and beyond, (2) developing regional guides that
    direct the management of its 155 national forests, (3) developing
    plans for managing each forest, and (4) reaching project-level
    decisions for implementing these plans.\1

    Environmental laws, enacted primarily during the 1960s and 1970s,
    hold the Forest Service accountable for the ecological consequences
    of its decisions by requiring the agency to protect natural resources
    such as threatened and endangered species, wetlands, air, water, and
    wilderness.

    --------------------
    \1 The Forest Service's decision-making process is explained in
    detail in app.  I.

       THE FOREST SERVICE'S MANAGEMENT
       IS DECENTRALIZED
    ---------------------------------------------------------- Chapter 1:1

    The Forest Service, created in 1905, is a hierarchical organization
    whose management is highly decentralized.  The Chief of the Forest
    Service heads the agency and, through Agriculture's Under Secretary
    for Natural Resources and Environment, reports to the Secretary of
    Agriculture.  Under the Chief, there are an associate chief and six
    deputy chiefs, including one responsible for the National Forest
    System.  In fiscal year 1995, the Forest Service received $3.4
    billion in appropriated funds, of which about $1.3 billion, or about
    38 percent, was allocated to the National Forest System.  The
    National Forest System received another $1.2 billion in fiscal year
    1995 from other sources--including moneys from trust funds and for
    fighting forest fires and fire protection, as well as credits for
    roads built by purchasers of timber sales, according to the Forest
    Service.  As a result, funding for the National Forest System totaled
    over $2.5 billion.  The system employs about 70 percent of the
    agency's approximately 36,000 personnel.

    Forest Service headquarters (Washington Office) primarily establishes
    policy and provides technical direction to the agency's three levels
    of field management--9 regional offices, 123 forest offices, and
    about 600 district offices.  At the Washington Office, the National
    Forest System has separate program directors for six different
    resources:  heritage and wilderness, range, recreation, timber,
    watershed and air, and wildlife and fisheries.  There is also a
    program director for planning.  Similar lines of resource management
    exist at the regional, forest, and district office levels.  However,
    because of budgetary constraints, the management of some resources
    may be combined.

    The nine regional offices, each managed by a regional forester,
    interpret policy and provide additional direction to the 123 forest
    offices that manage the 155 national forests.  Together, the Chief,
    the associate chief, the six deputy chiefs, the seven program
    directors, and the nine regional foresters make up the Forest
    Service's leadership team.

    The forests, together with 20 national grasslands and 17 national
    recreation areas, make up the National Forest System.  The forest
    offices, each managed by a forest supervisor, in turn, oversee the
    about 600 district offices, most of which are managed by a district
    ranger.  The forest supervisors are primarily responsible for
    developing and implementing management plans for their respective
    forest(s) which are approved by the appropriate regional forester.
    The district rangers are primarily responsible for implementing
    project-level decisions within their respective district.  At each
    level, managers have considerable autonomy and discretion for
    interpreting and applying the agency's policies and directions,
    guided by a system of manuals and handbooks keyed to statutes and
    regulations.

       Figure 1.1:  Lands Managed by
       the Forest Service in the 48
       Contiguous States

       (See figure in printed
       edition.)

       Source:  Forest Service.

       (See figure in printed
       edition.)

       NATIONAL FORESTS ARE MANAGED
       UNDER THE PRINCIPLES OF
       MULTIPLE USE AND SUSTAINED
       YIELD
    ---------------------------------------------------------- Chapter 1:2

    The Forest Service's motto is "caring for the land and serving
    people." Laws guiding the management of the National Forest System
    require the Forest Service to manage its lands under the principles
    of multiple use and sustained yield to meet the diverse needs of the
    American people.  The agency is required to plan for six renewable
    surface uses only--outdoor recreation, rangeland, timber, watersheds
    and water flows, wilderness, and wildlife and fish.  In addition, the
    Forest Service's guidance and regulations require that nonrenewable
    subsurface resources--such as oil, gas, and hardrock minerals--also
    be considered in preparing forest plans.\2

    Under the Organic Administration Act of 1897, the national forests
    are to be established to improve and protect the forests within their
    boundaries or to secure favorable water flow conditions and provide a
    continuous supply of timber to citizens.  The Multiple-Use
    Sustained-Yield Act of 1960 added the uses of outdoor recreation,
    range, watershed, and fish and wildlife.  This act also requires the
    agency to manage its lands to provide high levels of all of these
    uses to current users while sustaining undiminished the lands'
    ability to produce these uses for future generations (the
    sustained-yield principle).  Under the National Forest Management Act
    of 1976 (NFMA) and its implementing regulations, the Forest Service
    is to (1) recognize wilderness as a use of the forests and (2)
    maintain the diversity of plant and animal communities (biological
    diversity).

    --------------------
    \2 Federal Land Management:  Better Oil and Gas Information Needed to
    Support Land Use Decisions (GAO/RCED-90-71, June 27, 1990).

       THE FOREST SERVICE IS PART OF A
       LARGER FEDERAL LAND MANAGEMENT
       ORGANIZATIONAL STRUCTURE
    ---------------------------------------------------------- Chapter 1:3

    The federal government owns about 30 percent (about 650 million
    acres) of the nation's total surface area.  The Forest Service, in
    turn, manages about 192 million acres of land, or about 30 percent of
    all federal lands.  Forest Service lands include about one-fifth of
    the nation's forest lands.

    The Forest Service is one of four major federal land management
    agencies.  The other three are the National Park Service, the Bureau
    of Land Management, and the Fish and Wildlife Service, all within the
    Department of the Interior.  Together, the four agencies manage about
    95 percent of all federal lands.

    The Fish and Wildlife Service manages a loosely structured system of
    about 500 wildlife refuges encompassing about 89 million acres.
    These refuges are concentrated in Alaska and along four major
    north-south waterfowl migration flyways.  The agency manages its
    lands primarily to conserve and protect fish and wildlife and their
    habitat, although other uses--such as recreation (including hunting
    and fishing), mining and mineral leasing, livestock grazing, and
    timber harvesting--are allowed when they are compatible with the
    primary purposes for which the lands are managed.

    The National Park Service manages about 77 million acres, divided
    into 374 national parks and other units in 49 states.  The agency
    manages its lands to conserve, preserve, protect, and interpret the
    nation's natural, cultural, and historic resources for the enjoyment
    and recreation of current and future generations.

    The Bureau of Land Management manages about 270 million acres,
    divided into resource areas and located mainly in the West and in
    Alaska.  The Federal Land Policy and Management Act of 1976 requires
    the Bureau to manage its lands for multiple uses and sustained yield.
    The act defines multiple uses as recreation; range; timber; minerals;
    watershed; fish and wildlife; and natural, scenic, scientific, and
    historic values.

       FEDERAL LAND MANAGEMENT
       AGENCIES MUST COMPLY WITH
       ENVIRONMENTAL LAWS AND
       REGULATIONS
    ---------------------------------------------------------- Chapter 1:4

    All four of the major federal land management agencies must comply
    with the requirements of the National Environmental Policy Act of
    1969 (NEPA).  NEPA and its implementing regulations specify the
    procedures for integrating environmental considerations through
    environmental analyses and for incorporating public input into the
    agencies' decision-making processes.  NEPA requires that a federal
    agency prepare a detailed environmental impact statement (EIS) for
    every major federal action that may significantly affect the quality
    of the human environment.  The EIS is designed to ensure that
    important effects on the environment will not be overlooked or
    understated before the government makes a commitment to a proposed
    action.

    In developing plans and reaching project-level decisions, the four
    agencies must also comply with the requirements of other
    environmental statutes, including the Endangered Species Act, the
    Clean Water Act, the Clean Air Act, the Wilderness Act, and the
    Migratory Bird Treaty Act, as well as other laws, such as the
    National Historic Preservation Act.  The Forest Service is subject to
    more than 200 laws affecting its activities and programs.

    NEPA established the Council on Environmental Quality (CEQ) within
    the Executive Office of the President.  CEQ issued governmentwide
    regulations to implement the provisions of NEPA in 1978.  CEQ also
    assists federal departments and agencies in coordinating programs and
    activities that affect, protect, or improve environmental quality.
    The responsibility for implementing and enforcing environmental laws
    and regulations is dispersed among several federal regulatory
    agencies, as well as state and local agencies.  For example, the Fish
    and Wildlife Service and the Department of Commerce's National Marine
    Fisheries Service share the responsibility for ensuring the
    protection and recovery of threatened or endangered plant and animal
    species under the Endangered Species Act.  The Environmental
    Protection Agency (EPA) has authorities and responsibilities to
    implement major environmental statutes, including those to protect
    and enhance air quality (the Clean Air Act) and to restore and
    maintain the chemical, physical, and biological integrity of the
    nation's waters (the Clean Water Act).  The U.S.  Army Corps of
    Engineers has authority under the Clean Water Act to regulate
    activities in wetlands and other waters of the United States.

       THE FOREST SERVICE MUST INVOLVE
       THE PUBLIC IN ITS
       DECISION-MAKING
    ---------------------------------------------------------- Chapter 1:5

    Both NEPA and NFMA and their implementing regulations require the
    Forest Service to involve the public in its decision-making process.
    In addition, NFMA requires the Secretary of Agriculture to establish
    and consult with advisory committees under the Federal Advisory
    Committee Act (FACA), as amended, if they are deemed "necessary to
    secure full information and advice." Passed in 1972, FACA was enacted
    to control the advisory committee process and to open to public
    scrutiny the manner in which government agencies obtain advice from
    private individuals and groups.  FACA applies to formally organized
    committees or similar groups that the President or an executive
    department or official directs to provide advice or make
    recommendations.  An advisory committee chartered under FACA must
    take a number of steps to ensure open public meetings.  These steps
    include publishing timely notice of meetings in the Federal Register,
    holding meetings in public, making detailed minutes of the meetings
    available to the public, and allowing interested persons to appear
    before the committee.

       OBJECTIVES, SCOPE, AND
       METHODOLOGY
    ---------------------------------------------------------- Chapter 1:6

    Concerned about the costs, time, and complexity of the Forest
    Service's decision-making (see ch.  2), the Chairmen of the Senate
    Committee on Energy and Natural Resources and its Subcommittee on
    Forests and Public Land Management; the Chairman of the Subcommittee
    on National Parks, Forests, and Lands, House Committee on
    Resources;\3 the Chairman of the Subcommittee on Interior, House
    Committee on Appropriations; and Senator Conrad Burns asked us to
    identify and examine the decision-making process used by the Forest
    Service in carrying out its mission.  (See app.  I.) They have also
    asked us to testify on issues and options relating to the process.\4

    In this report, we discuss the internal and external causes of
    inefficiency and ineffectiveness in the Forest Service's
    decision-making process:  (1) the inadequate attention that the
    Forest Service has given to improving the process; (2) the lack of
    agreement, both inside and outside the agency, on how it is to
    resolve conflicts among competing uses on its lands; (3) unresolved
    interagency issues that transcend the Forest Service's administrative
    boundaries and jurisdiction; and (4) differences in the requirements
    of laws that help frame its decision-making.  As agreed with the
    requesters' offices, we focused our work primarily on the
    relationship between the agency's timber production and other uses on
    the national forests.

    To identify the decision-making process used by the Forest Service in
    carrying out its mission, we reviewed applicable laws and their
    legislative histories, regulations implementing the laws, executive
    orders, agency directives, and court cases.  We also met with Forest
    Service headquarters and field managers and staff, headquarters and
    regional attorneys from Agriculture's Office of the General Counsel,
    and staff and counsel from CEQ.

    To identify issues relating to the Forest Service's decision-making
    process and options to address them, we met with and reviewed
    documents provided by (1) officials in the Office of the Secretary of
    Agriculture and (2) the Chief of the Forest Service and other Forest
    Service headquarters and field personnel.  During the course of our
    review, we visited 14 forests and one forest experiment station in 8
    regions.  We met with managers and staff from these units and from 24
    ranger districts located on the forests that we visited.  (See app.
    II for a list of these regions, forests, and ranger districts.) We
    also met with or contacted, and obtained documents from, headquarters
    and field managers and staff in EPA; Interior's Bureau of Land
    Management, National Park Service, and Fish and Wildlife Service; and
    Commerce's National Marine Fisheries Service.

    We met with or contacted, and reviewed documents provided by,
    national and local officials and staff of professional forestry,
    timber and livestock industry, environmental, and recreational
    organizations, as well as academic and other natural resource policy
    analysts and officials from state and local governments and Native
    American tribes.  (See app.  III for the organizations contacted
    during this review.) In addition, we conducted a literature search
    and reviewed recent books and professional and scientific journal
    articles on federal land management.

    We reviewed program and budget data for the Forest Service since its
    creation in 1905.  We concentrated on the period since 1960, when the
    Multiple-Use Sustained-Yield Act was enacted, and especially on the
    period since 1976, when the National Forest Management Act was
    passed.

    We also reviewed studies and reports prepared by the Forest Service
    and others, as well as legislation being considered by the Congress.
    We identified "best practices" evolving within the Forest Service
    that could improve efficiency or effectiveness if implemented
    agencywide.  In addition, we attended various forums, conferences,
    workshops, and interagency meetings at which issues and options
    relating to the Forest Service's decision-making were discussed.

    We performed our work primarily from August 1995 through March 1997
    in accordance with generally accepted government auditing standards.
    In conducting our work, we did not independently verify or test the
    reliability of the data provided by the Forest Service or others.  We
    obtained comments on a draft of this report from the Forest Service
    and CEQ.  These agencies' comments and our responses are presented in
    appendixes IV and V.

    --------------------
    \3 In the 105th Congress, this Subcommittee was split into a
    Subcommittee on Forests and Forest Health and a Subcommittee on
    National Parks and Public Lands.

    \4 Forest Service:  Issues Relating to Its Decisionmaking Process
    (GAO/T-RCED-96-66, Jan.  25, 1996), Forest Service:  Issues Related
    to Managing National Forests for Multiple Uses (GAO/T-RCED-96-111,
    Mar.  26, 1996), and Forest Service Decision-Making:  Greater Clarity
    Needed on Mission Priorities (GAO/T-RCED-97-81, Feb.  25, 1997).

    THE FOREST SERVICE'S
    DECISION-MAKING PROCESS IS COSTLY
    AND TIME-CONSUMING, OFTEN FALLING
    SHORT OF EXPECTATIONS
    ============================================================ Chapter 2

    Some Members of Congress are concerned about the costs, time, and
    complexity of the Forest Service's decision-making process.  They are
    also concerned that the Forest Service often has not been able to
    achieve the objectives in its forest plans.  Hearings held during the
    104th Congress identified opportunities to improve the efficiency and
    effectiveness of the Forest Service's decision-making.

       THE FOREST SERVICE'S
       DECISION-MAKING PROCESS IS
       COSTLY AND TIME-CONSUMING
    ---------------------------------------------------------- Chapter 2:1

    The last of the 123 forest plans covering all 155 forests in the
    National Forest System was approved in 1995, and the first plans,
    approved in the early 1980s, are due for revision.  Forest plans have
    generally taken from 3 to 10 years to complete, and recent plans for
    forests in the Pacific Northwest have cost between $5 million and $8
    million to develop.  Amending or revising forest plans can also be
    costly and time-consuming.  For instance, the Black Hills National
    Forest in South Dakota estimates that it has spent over 7 years and
    more than $3 million revising its plan, which still has not been
    approved.

    In addition, the Forest Service spends more than $250 million a year
    conducting environmental analyses and preparing environmental
    documents to support project-level decisions, according to a Forest
    Service reengineering team.\1 In 1995, the Forest Service reported
    that it prepared about 20,000 environmental documents annually--more
    than any other federal agency.  In 1994 (the last year for which data
    are available) the Forest Service issued almost 20 percent of all the
    final environmental impact statements prepared by federal agencies
    (50 out of a total of 253).  According to the reengineering team,
    conducting environmental analyses and preparing environmental
    documents consumes about 18 percent of the funds available to manage
    the national forests and approximately 30 percent of the agency's
    field resources.

    The costs and time required to complete environmental analyses and
    prepare environmental documents have increased for individual
    projects.  The Forest Service's costs to undertake timber sales have
    tripled since 1988, and a sale can take up to 8 years to prepare.
    (See fig.  2.1.)

       Figure 2.1:  Costs to Undertake
       Timber Sales, 1973-94

       (See figure in printed
       edition.)

    Source:  Forest Service.

    For example, preparation for the La Manga timber sale on the Carson
    National Forest in New Mexico began in 1987.  The environmental
    analysis was conducted between July 1990 and March 1994.  On the
    basis of the analysis, the forest decided to offer approximately 4.2
    million board feet with an estimated value of about $718,000.  The
    decision was appealed and litigated.  On the basis of new information
    on wildlife in the sale area and a plan by the Fish and Wildlife
    Service to recover the threatened Mexican spotted owl, the forest
    reduced the volume of timber to be offered to 2.4 million board feet
    with an estimated value of about $411,000.  According to forest
    officials, they spent an estimated $300,000 conducting the original
    environmental analysis and an additional $400,000 responding to legal
    challenges, updating information, and reanalyzing the sale area.
    These estimates do not include the costs of using attorneys within
    Agriculture's Office of the General Counsel to defend the agency or
    of postponing other projects on the forest to allow staff and
    resources to be assigned to the La Manga project.

    According to the Forest Service, it conducts extensive, complex
    environmental analyses in order to comply with the requirements of
    the National Environmental Policy Act (NEPA) and other environmental
    laws and to avoid or prevail against challenges to its compliance
    with these laws.  Despite these analyses, the Forest Service receives
    over 1,200 administrative appeals to project-level decisions
    annually, and about 20 to 30 new lawsuits are filed each year.  Many
    of these appeals and lawsuits are by parties seeking to delay,
    modify, or stop plans or projects that they oppose.

    Although compliance with planning and environmental laws is costly
    and time-consuming, noncompliance is also, as two examples
    demonstrate.

      -- From October 1992 through June 1996, the Forest Service paid
         almost $6.5 million in claims for timber sale contracts that
         were suspended or canceled to protect endangered or threatened
         species.  As of October 1996, the agency had pending claims with
         potential damages of about $61 million, and it could incur at
         least an additional $198 million in damages.  Some of these
         contracts were suspended or canceled because the Forest Service
         had not developed plans that satisfied the requirements of laws
         such as NEPA, the National Forest Management Act, or the
         Endangered Species Act.\2 Forest Service officials believe that
         additional congressional funding is needed to help pay for the
         increased costs.  In December 1996, Forest Service headquarters
         directed the agency's nine regional offices to plan and budget
         for fiscal year 1997 on the assumption that the Congress would
         approve a supplemental appropriation to pay for the increased
         costs.

      -- The Forest Service could incur significant costs because the
         Eldorado National Forest in northern California failed to comply
         with the requirements of planning and environmental laws.
         Forest officials decided to proceed with a number of timber
         sales on the basis of cursory, out-of-date environmental
         assessments that did not adequately analyze the sales' potential
         effects on fish, wildlife, plants, cultural resources, and water
         quality and did not consider significant new information, as
         required under NEPA regulations.  The contracts that were
         awarded have since been suspended.  As a result, the Forest
         Service could incur $30 million in potential damages.

    --------------------
    \1 Final Report of Recommendations:  Project-Level Analysis
    Re-Engineering Team (Nov.  17, 1995).  The team, consisting primarily
    of regional and forest-level personnel, was tasked by the Forest
    Service with designing a new process for conducting project-level
    environmental analyses.

    \2 Timber Management:  Opportunities to Limit Future Liability for
    Suspended or Canceled Timber Sale Contracts (GAO/RCED-97-14, Oct.
    31, 1996).

       OBJECTIVES IN FOREST PLANS
       OFTEN HAVE NOT BEEN ACHIEVED
    ---------------------------------------------------------- Chapter 2:2

    After spending over 20 years and over $250 million to develop forest
    plans, the Forest Service often has not been able to achieve the
    plans' objectives.  As a result, the public has not been able to form
    reasonable expectations about the health of forests over time or
    about the future availability of forest uses.

    In 1991, for example, we reported that the Forest Service had
    approved the plan for the Flathead National Forest in northwestern
    Montana in 1986 but had fallen short of the plan's timber-offering
    goal by about 37 percent during the first 5 fiscal years covered by
    the plan.\3 The forest has continued to fall short of its goal.
    Similarly, in 1994, we reported that timber sales on five forests we
    reviewed were below the goals identified in the plans for fiscal
    years 1991 through 1993.\4 (See table 2.1.) Three of the forests--the
    Deschutes and Mt.  Hood in Oregon and the Gifford Pinchot in
    Washington--are in the Forest Service's Pacific Northwest Region.
    The other two forests--the Ouachita in Arkansas and the
    Chattahoochee-Oconee in Georgia--are in the Forest Service's Southern
    Region.  These two regions sold more timber in fiscal year 1993 than
    the Forest Service's other seven regions.

                                   Table 2.1

                    Comparison of Average Annual Timber Sale
                     Goals and Timber Sale Volumes for Five
                                National Forests

                       (Volume in millions of board feet)

                                                Timber sale volume
                                        ----------------------------------
                                Timber
    Forest                        goal        1991        1992        1993
    ----------------------  ----------  ----------  ----------  ----------
    Deschutes                     97.8        18.3        26.7        12.7
    Gifford Pinchot              334.0       110.2        19.8        14.8
    Mt. Hood                     189.0        50.6        28.2        38.1
    Chattahoochee-Oconee         101.5        63.3        54.1        49.2
    Ouachita                     146.7        39.8        95.8       131.2
    ----------------------------------------------------------------------
    The Forest Service approved the forest plans for the Deschutes,
    Gifford Pinchot, and Mt.  Hood forests in 1991.  However, the volume
    of timber sold fell short of the plans' timber goals by about 83
    percent during the first 3 fiscal years covered by the plans.  The
    forest plan for the Chattahoochee-Oconee was approved in 1986.
    However, as a result of an administrative appeal, forest officials
    agreed in 1986 to limit average annual timber sales to 87 million
    board feet.  The volume of timber sold fell short of the plan's
    revised timber goal by about 36 percent during fiscal years 1991
    through 1993.  The forest plan for the Ouachita was approved in 1987
    and amended in 1990.  At that time, the plan's timber goal was
    lowered from 159.0 million board feet to 146.7 million board feet.
    The volume of timber sold fell short of the plan's amended timber
    goal by about 39 percent during fiscal years 1991 through 1993.

    At some of the forests visited during this review, we found that the
    Forest Service had either (1) revised or amended its plans to
    significantly reduce the timber goals or (2) acknowledged that the
    goals could not be met.  For example, the Nantahala-Pisgah National
    Forest in North Carolina had reduced its yearly timber goal from 72
    to 34 million board feet, or by 54 percent, and the Black Hills
    National Forest in South Dakota was reducing its yearly timber goal
    from 160 to 100 million board feet, or by 38 percent.  In addition,
    the Nicolet National Forest in Wisconsin acknowledged that it could
    produce about 42 million board feet per year rather than the 97
    million board feet established as a goal in its forest plan.

    The Forest Service has also not met its objectives for sustaining
    wildlife.  When actions designed to benefit wildlife have been
    included in approved forest plans, they have usually been implemented
    only partially or not at all.  For example, between February 1988 and
    August 1990, we examined 51 Forest Service and Bureau of Land
    Management plans containing 1,130 wildlife-related action items
    scheduled to have been conducted before our review.  Of these, 39
    percent had not been started, 22 percent had been partially
    completed, and 33 percent had been fully completed, according to the
    available documentation.\5 (See fig.  2.2.)

       Figure 2.2:  Disposition of
       Wildlife-Related Actions in 51
       Forest Service and Bureau of
       Land Management Plans

       (See figure in printed
       edition.)

    --------------------
    \3 Forest Service:  The Flathead National Forest Cannot Meet Its
    Timber Goal (GAO/RCED-91-124, May 10, 1991).

    \4 Forest Service:  Factors Affecting Timber Sales in Five National
    Forests (GAO/RCED-95-12, Oct.  28, 1994).

    \5 Public Land Management:  Attention to Wildlife Is Limited
    (GAO/RCED-91-64, Mar.  7, 1991).

       OPPORTUNITIES EXIST TO IMPROVE
       THE EFFICIENCY AND
       EFFECTIVENESS OF THE FOREST
       SERVICE'S DECISION-MAKING
    ---------------------------------------------------------- Chapter 2:3

    Recent GAO work has found that reengineering inefficient work
    processes offers unprecedented opportunities to improve the delivery
    of government services and reduce the costs of programs.\6 Studies by
    the Forest Service support this finding.  For example, according to
    the Forest Service reengineering team, improvements to the agency's
    process for conducting environmental analyses could improve
    timeliness and reduce costs by 10 to 15 percent initially and by 30
    to 40 percent over time.  Similarly, a Forest Service team, tasked
    with developing and implementing a more efficient way of managing the
    process of issuing livestock grazing permits, estimates that the
    model it designed (referred to as the adaptive learning model) could
    improve the timeliness of the process by 40 percent.

    A reduction of 30 to 40 percent in the costs of the process used by
    the Forest Service to reach project-level decisions could reduce the
    costs of its decision-making by between $75 million and $100 million
    a year and reduce the time needed to complete some timber sales by up
    to 2 and 3 years.  Officials at many regions and forests we visited
    during this review stated that reducing the costs and time of
    decision-making would, in turn, provide more resources to achieve the
    objectives in the forest plans.  However, as discussed in the
    following chapters, improving the efficiency and effectiveness of the
    Forest Service's decision-making process will require that (1) the
    agency give adequate attention to improving accountability for
    expenditures and performance, (2) agreement be reached on how the
    agency is to resolve conflicts among competing uses on its lands, (3)
    the Council on Environmental Quality and the major federal land
    management agencies address interagency issues that transcend the
    Forest Service's administrative boundaries and jurisdiction, and (4)
    a systematic and comprehensive analysis be performed to resolve
    differences in the requirements of laws that help frame the agency's
    decision-making.

    --------------------
    \6 Managing for Results:  Steps for Strengthening Federal Management
    (GAO/T-GGD/AIMD-95-158, May 9, 1995).

    THE FOREST SERVICE HAS NOT GIVEN
    ADEQUATE ATTENTION TO IMPROVING
    ITS DECISION-MAKING PROCESS
    ============================================================ Chapter 3

    Some of the inefficiency in developing forest plans and reaching
    project-level decisions, as well as the ineffectiveness in achieving
    the plans' objectives, has occurred because the Forest Service has
    not given adequate attention to improving its decision-making
    process, including improving its accountability for expenditures and
    performance.  As a result, the Forest Service must request more funds
    to accomplish fewer objectives during the yearly budget and
    appropriation process.  In addition, long-standing deficiencies
    within the decision-making process, which have contributed to
    increased costs and time and/or limited the ability to achieve
    planned objectives, have not been corrected.  These deficiencies
    include (1) not adequately monitoring the effects of past management
    decisions, (2) not maintaining comparable environmental and
    socioeconomic data that are useful and easily accessible to forest
    managers, and (3) not adequately involving the public throughout the
    decision-making process.  However, landmark legislation enacted in
    the 1990s, if implemented successfully, will strengthen
    accountability within the Forest Service and improve the efficiency
    and effectiveness of its decision-making.

       THE FOREST SERVICE IS NOT
       SUFFICIENTLY ACCOUNTABLE FOR
       ITS EXPENDITURES
    ---------------------------------------------------------- Chapter 3:1

    The Chief Financial Officers Act of 1990 requires federal agencies to
    be more accountable for their expenditures of appropriated funds by
    requiring them to (1) develop integrated accounting and financial
    management systems that are to provide complete, reliable,
    consistent, and timely financial information and (2) provide for the
    systematic measurement of performance.  Improved accountability for
    expenditures is particularly important within the Forest Service
    since the Congress has increased the agency's flexibility in fiscal
    decision-making.  Beginning in fiscal year 1995, the Congress (1)
    simplified the Forest Service's budget structure, reducing the number
    of main appropriations from 13 to 9 and of funding items from 71 to
    44, and (2) expanded the agency's reprogramming authority, giving it
    greater discretion in shifting funds between line items within each
    appropriation.  However, this increased flexibility has not been
    accompanied by increased accountability in budget execution through
    better accounting for expenditures, and the Forest Service has made
    little progress in implementing the provisions of the Chief Financial
    Officers Act.

    An audit of the Forest Service's financial statements for fiscal year
    1995 by Agriculture's Inspector General resulted in an adverse
    opinion because of "pervasive errors, material or potentially
    material misstatements, and/or departures from applicable Government
    accounting principles affecting Financial Statement accounts."\1 On
    the basis of this opinion, Agriculture reported that it could not
    provide reasonable assurance of the integrity of the Forest Service's
    management, accounting, and administrative control systems.

    Our work, as well as that of the Inspector General, has also
    identified shortcomings in the Forest Service's accounting and
    financial data and information systems that preclude the agency from
    presenting accurate and complete financial information.  These
    shortcomings include (1) various material weaknesses in the internal
    controls for financial management that result in a lack of accurate
    and reliable information and (2) accounting codes that do not
    accurately assign or track all costs to each resource program.

    For example, in June 1996 we reported that the Forest Service was
    unable to provide us with data showing the costs and revenues of
    management activities being carried out at each of the national
    forests because of shortcomings in its accounting and financial
    information systems.  According to the Forest Service's Associate
    Deputy Chief for Administration, the current system for maintaining
    cost data does not enable the agency to associate the costs incurred
    in generating revenues from various forest uses.\2 The shortcomings
    identified in our June 1996 report had been identified and reported
    by the Inspector General over the previous few years.

    The Inspector General's audit of the Forest Service's financial
    statements for fiscal year 1995 found that the costs for firefighting
    personnel and equipment had been incorrectly charged by one regional
    office to other activities, resulting in overexpenditures of about
    $6.7 million by the region.  The Inspector General reported that,
    overall, the Forest Service could not determine for what purposes
    $215 million of its $3.4 billion in operating and program funds were
    spent in fiscal year 1995.  As a result, Forest Service managers are
    unable to adequately monitor and control spending levels for various
    programs and activities relating to decision-making or to measure the
    extent to which changes affect costs and efficiency.\3

    As evidenced above, the Forest Service has either (1) not implemented
    corrective actions intended to hold it fiscally accountable for its
    decisions, stating that these actions would be too difficult or
    costly to implement, or (2) stopped monitoring corrective actions
    before they were completed.  For example, agency officials informed
    us that they believe it would be difficult and costly to develop
    information systems that have the capability to produce the
    sale-by-sale information on obligations and expenditures needed to
    ensure compliance with a legislative prohibition against expending
    more funds for reforestation and other related activities on a timber
    sale area than have been collected from that sale area.\4

    Moreover, in an audit of the Forest Service's fiscal year 1995
    financial statements, the Inspector General stated that the Forest
    Service had stopped monitoring actions to improve the internal
    controls over its timber sale program and charge-as-worked fund usage
    (ensuring the use of proper accounting code charges) before the
    actions were completed.  As a result, the agency does not know
    whether the corrective actions were ever implemented.

    After Agriculture's Inspector General concluded that the agency's
    fiscal year 1995 financial statements were unreliable, the Forest
    Service established a working group to address these and other
    accounting and financial reporting problems.  However, corrective
    actions to address accounting and financial reporting problems
    identified by the Inspector General are not scheduled to be
    implemented until the end of fiscal year 1998.

    --------------------
    \1 Audit of Forest Service's Fiscal Year 1995 Financial Statements,
    U.S.  Department of Agriculture (USDA), Office of the Inspector
    General, Audit Report No.  08401-4-At.

    \2 Forest Service's Financial Data Limitations (GAO/RCED-96-198R,
    June 19, 1996).

    \3 Forest Service (GAO/AIMD-97-11R, Dec.  20, 1996).

    \4 Forest Service's Reforestation Funding:  Financial Sources, Uses,
    and Condition of the Knutson-Vandenberg Fund (GAO/RCED-96-15, June
    21, 1996).

       THE FOREST SERVICE IS NOT
       SUFFICIENTLY ACCOUNTABLE FOR
       ITS PERFORMANCE
    ---------------------------------------------------------- Chapter 3:2

    The Forest Service has also made little progress in holding its
    managers accountable for their performance.  Holding managers
    accountable implies a consequence for a certain decision and fixes
    the responsibility for outcomes.

    For example, in its June 1990 Critique of Land Management Planning,\5
    the Forest Service stated that, while the Congress should increase
    the agency's flexibility in fiscal decision-making, it should not
    expect the agency to be accountable for its performance.
    Specifically, the critique stated that "Congress must put its money
    where its statute is," but "this should be done without any further
    complication of the system through the introduction of new 'resource
    output goals' that are problematic to define and are of dubious value
    in program evaluation." The critique continued that "meaningful
    production goals for recreation, water, wildlife, and fisheries have
    yet to be established, even in theory, and reported accomplishments
    would be nearly impossible to evaluate objectively or even verify
    independently."

    In response to congressional concerns about the Forest Service's
    inability to deliver what is expected or promised, the Chief, in the
    fall of 1991, formed a task force of employees from throughout the
    agency to review the issue of accountability.  The task force's
    February 1994 report\6 stated that 60 percent of the findings by GAO
    and Agriculture's Inspector General focused on the inability of the
    Forest Service either to do what it agreed or was directed to do, or
    to do the task in question as it said it would.  According to the
    task force, audits by GAO and the Inspector General confirmed that
    the agency can and does identify problems but is slow to take
    corrective action.  This was especially true for internal Forest
    Service reviews.  The task force observed that when external
    attention is not focused on an issue, "corrective action is not a top
    priority." Only an external review prompts corrective action,
    according to the task force, even when the Forest Service has already
    identified the problems disclosed through the external audit.

    Using the information gathered, the task force defined accountability
    as "being answerable for what we do" and determined that in order to
    be accountable, the agency "must do what we agreed or were directed
    to do as we agreed or are required to do it, monitor and show our
    results, and take action to improve results." The report set forth a
    seven-step process to strengthen accountability.  Steps in the
    process included (1) establishing work agreements that include
    measures and standards with customers' involvement, (2) assessing
    performance, and (3) communicating results to customers.

    The report noted that the evidence supporting the need for increased
    accountability was "compelling" and that improving accountability for
    performance would not require a major financial outlay.  Rather, the
    report called for a significant commitment on the part of the agency
    to change.  To help the Forest Service change its behavior, the task
    force recommended that the agency (1) institutionalize its
    expectations for corporate accountability in the work agreements
    established with customers' involvement, (2) accelerate cultural
    change, and (3) monitor and track accountability through indicators
    or benchmarks.

    The concepts in the task force's report were adopted by the Forest
    Service's leadership team and distributed agencywide.  However,
    without external attention, the task force's recommendations were
    never implemented throughout the agency.  As a result, the agency has
    never fulfilled its stated goal to "achieve a leadership and
    organizational culture in which responsibility and accountability for
    excellence are shared by all employees in the execution of the Forest
    Service's mission." Rather, the task force's recommendations were
    identified in the agency's October 1995 draft long-term strategic
    plan as an effort to be implemented over the next decade.\7

    --------------------
    \5 Critique of Land Management Planning, Vol.  2, National Forest
    Planning:  Searching for a Common Vision, Forest Service (FS-453,
    June 1990).

    \6 Individual and Organizational Accountability in the Forest
    Service:  Successful Management of Work Agreements, USDA, Forest
    Service (Feb.  1994).

    \7 The Forest Service Program for Forest and Rangeland Resources:  A
    Long-Term Strategic Plan, Draft 1995 RPA Program, USDA, Forest
    Service, Washington Office (Oct.  16, 1995).

       THE FOREST SERVICE MUST REQUEST
       MORE FUNDS TO ACCOMPLISH FEWER
       OBJECTIVES
    ---------------------------------------------------------- Chapter 3:3

    Because the Forest Service has made little progress in holding
    managers accountable for their expenditures and performance, it must
    request more funds to accomplish fewer objectives in forest plans
    during the yearly budget and appropriation process.  The Congress, in
    fiscal year 1991, asked the Forest Service to develop a multiyear
    program to reduce the costs of its timber program by not less than 5
    percent per year.  The Forest Service responded to these and other
    concerns by undertaking a cost-reduction study and issuing a report
    in April 1993.\8 However, the agency left the implementation of
    field-level action items to the discretion of each of its nine
    regional offices, and while some regions rapidly pursued the goal of
    becoming cost-efficient, others did not.\9 A second Forest Service
    report, issued in January 1995, examined policy options to improve
    the timber program's cost-efficiency.\10 However, the report's
    recommendations have not been implemented.  Implementing the November
    1995 recommendations of the Forest Service reengineering team,
    designed to correct weaknesses in the agency's project-level
    environmental analyses, would go a long way toward reducing the costs
    of the agency's timber program.  However, at the end of 1996, the
    Forest Service had not acted to implement any of the team's
    recommended improvements agencywide.

    With no incentive to act, the Forest Service is preparing to
    undertake the third major examination of its timber program in the
    last 4 years.  Meanwhile, the costs associated with preparing and
    administering timber sales have continued to rise.  (See ch.  2.) As
    a result, for fiscal year 1998, the agency is requesting $12 million
    (6 percent) more for timber sales management than was appropriated
    for fiscal year 1997 while proposing to offer 0.4 billion board feet
    (10 percent) less timber for sale.  Given such a trend, some Forest
    Service officials expressed concern that the costs to prepare and
    administer some timber sales may exceed the gross receipts derived
    from them.

    Moreover, without being held accountable for their performance in
    reaching decisions, some Forest Service managers have become more
    concerned about legal challenges to plans and projects than about the
    costs and time required to reach the decisions.  For example,
    according to the Forest Service, it conducts extensive, complex
    environmental analyses not only to comply with the requirements of
    the National Environmental Policy Act (NEPA) and other environmental
    laws but also to avoid or prevail against challenges to its
    compliance with these laws.  In its 1995 report,\11 the Forest
    Service reengineering team, tasked with designing a new process for
    conducting project-level environmental analyses, noted that the
    agency sometimes conducts (1) environmental assessments and studies
    and prepares environmental documents for decisions that are
    noncontroversial and/or could be categorically excluded from
    environmental analysis and (2) redundant analyses instead of focusing
    on what is new and using existing analyses to support new decisions
    when possible.

    --------------------
    \8 Timber Cost Efficiency Study--Final Report (Apr.  16, 1993).

    \9 Forest Service:  Status of Efforts to Achieve Cost Efficiency
    (GAO/RCED-94-185FS, Apr.  26, 1994).

    \10 Timber Program Issues:  A Technical Examination of Policy Options
    (Jan.  1995).

    \11 Final Report of Recommendations:  Project-Level Analysis
    Re-Engineering Team (Nov.  17, 1995).

       THE FOREST SERVICE HAS NOT
       CORRECTED LONG-STANDING
       DEFICIENCIES IN ITS
       DECISION-MAKING PROCESS
    ---------------------------------------------------------- Chapter 3:4

    Because the Forest Service has not been held sufficiently accountable
    for its expenditures and performance, it has not corrected
    long-standing deficiencies in its decision-making process.  These
    deficiencies, which have driven up costs and time and/or driven down
    the agency's ability to achieve planned objectives, center on
    inadequate monitoring, data, and public involvement.

    Many of the studies and reports that have addressed these
    deficiencies within the Forest Service's decision-making process have
    also recommended improvements--some of which reflect best practices
    evolving in the field.  Generally, these changes require nothing more
    than involving the appropriate parties at the appropriate times and
    basing decisions on sound information.  However, the Forest Service
    has either ignored the recommended improvements or left their
    implementation to the discretion of regional offices and forests.  As
    a result, their implementation has been uneven and their results
    mixed.

          MONITORING AND EVALUATION
          ARE NOT PERFORMED
    -------------------------------------------------------- Chapter 3:4.1

    Regulations implementing the National Forest Management Act (NFMA)
    require the Forest Service to monitor and assess the effects of its
    management practices on the lands' productivity.  Adequate monitoring
    of the effects of past management decisions is critical to accurately
    estimate the effects of similar future decisions, including their
    cumulative impact on the environment.

    Moreover, monitoring can be used as an effective tool when the
    effects of a decision may be difficult to determine in advance
    because of uncertainty or costs.  Regulations implementing NEPA
    provide that when information relevant to reasonably foreseeable
    significant adverse effects is incomplete or unavailable, an agency
    shall--in the environmental impact statement accompanying the
    decision--(1) acknowledge this gap, (2) explain the relevance of the
    missing information, (3) summarize the scientific evidence available,
    and (4) evaluate the potential effects of the decision using research
    methods or approaches that are generally accepted in the scientific
    community.  According to an interagency task force chaired by the
    Council on Environmental Quality (CEQ),\12 the agency can then
    condition the decision on the monitoring of uncertainties, indicate
    how the decision will be modified when new information is uncovered
    or when preexisting monitoring thresholds are crossed, and reexamine
    the decision in light of its results or when a threshold is crossed.
    According to the task force, if an agency spells out contingencies
    ahead of time and if others have had an opportunity to comment,
    management changes can be made without supplementing the NEPA
    analysis, as long as the changes and their associated effects have
    already been analyzed under the statute.

    When the Forest Service proposed revisions to its planning
    regulations in April 1995,\13 it stated that an expanded and
    strengthened role for monitoring and evaluation was a "cornerstone"
    for implementing the proposed rule.  Moreover, many Forest Service
    officials with whom we spoke, as well as several studies we reviewed,
    stated that monitoring and evaluation could be more efficient and
    effective than attempting to predict a project's outcome before
    implementing a project-level decision.

    However, the Forest Service has historically given low priority to
    monitoring during the annual competition for scarce resources.  In
    addition, almost 7 years after publishing its Critique of Land
    Management Planning,\14 which identified the need to improve
    monitoring, the Forest Service continues to approve projects that do
    not provide adequately for monitoring.  Moreover, the agency
    generally does not monitor implementation of its plans as its
    regulations require.  For example, in fiscal year 1995, only 78, or
    63 percent, of 123 required annual monitoring and evaluation plans
    were prepared.

    While the proposed revisions to the Forest Service's planning
    regulations state that projects to implement forest plans cannot be
    undertaken unless there is a "reasonable expectation" that adequate
    funding will be available to conduct monitoring and evaluation
    activities, they do not state how this determination will be made or
    who will be held accountable for making it.  Moreover, monitoring
    programs that are funded may not be designed carefully enough to
    provide information of the kind or in the form that is most useful
    for evaluating past decisions and aiding in future decision-making.
    Several Forest Service officials told us that simplified, less costly
    monitoring plans with fewer, more well-chosen measurements could
    provide most of the information needed to determine the environmental
    effects of past management decisions.  However, they also noted that
    because the need for improved monitoring was so widespread within the
    agency, adequate monitoring agencywide will likely require more
    resources than are currently being committed.

    In a March 1991 report,\15 we stated that although the Forest
    Service's regulations required the agency to monitor the
    implementation of its forest plans, it had generally not done so.  It
    had not collected comprehensive data on the current conditions of
    wildlife habitat and population trends for the thousands of wildlife
    species using public lands.  Not having these data had precluded it
    from assessing the health of wildlife on public lands or the effects
    of federal management efforts.

    Similarly, in October 1996, an interagency team that reviewed an
    emergency salvage timber sales program\16 reported significant gaps
    in carrying out the agreement's direction on field monitoring.\17
    Gaps were identified in the effectiveness of (1) mitigation measures,
    (2) requirements and limitations, and (3) other project design
    features intended to ensure that activities are environmentally
    sound.

    Not monitoring and evaluating its decisions could further increase
    the costs and time of decision-making by exposing the Forest Service
    to additional litigation.  Specifically, the agency could be subject
    to claims of noncompliance with the monitoring requirements of NFMA.
    For example, a legal challenge filed against the agency in 1996
    alleged inadequate monitoring of the results of the plan for the
    Shoshone National Forest in Wyoming.  Although the agency settled the
    suit by agreeing to improve its monitoring, the Chief of the Forest
    Service told us that the agency's failure to monitor represents a
    potential major future litigation liability to the agency.  He and
    other Forest Service officials noted that, in dismissing a challenge
    to the President's plan for the national forests in the Pacific
    Northwest, the federal district court judge stated that the court
    would entertain further litigation based on allegations that the
    Forest Service had failed to live up to its monitoring
    requirements.\18

    Furthermore, the Forest Service's historical noncompliance with the
    monitoring requirements of regulations implementing NFMA diminishes
    the chances that the public and federal regulatory agencies will
    trust the agency to fulfill its monitoring requirements in the
    future.  Several environmental groups told us that they were
    concerned about the Forest Service's lack of monitoring on national
    forests.  As a result, they will continue to insist that the Forest
    Service prepare detailed environmental analyses and
    documentation--which have become increasingly costly and
    time-consuming--before reaching project-level decisions rather than
    support what many Forest Service officials believe to be the more
    efficient and effective option of monitoring and evaluation.  Thus,
    the Forest Service's past failure to monitor represents a lost
    opportunity to reduce the costs and time of future decision-making.

    --------------------
    \12 The Ecosystem Approach:  Healthy Ecosystems and Sustainable
    Economies, Vol.  II, Implementation Issues, Interagency Ecosystem
    Management Task Force (Nov.  1995).

    \13 60 Fed.  Reg.  18886 (Apr.  13, 1995).

    \14 Critique of Land Management Planning, Vol.  5, Public
    Participation (FS-456, June 1990).

    \15 Public Land Management:  Attention to Wildlife Is Limited
    (GAO/RCED-91-64, Mar.  7, 1991).

    \16 "Salvage" timber generally refers to timber that is being made
    available for harvest because it is disease- or insect-infested,
    dead, damaged, downed by wind, affected by fire, or imminently
    susceptible to fire or insect attack.

    \17 Interagency Salvage Program Review, U.S.  Department of Commerce,
    National Oceanic and Atmospheric Administration, National Marine
    Fisheries Service (Silver Spring, Maryland:  Oct.  8, 1996).  The
    five agencies were the National Marine Fisheries Service, the Forest
    Service, the Bureau of Land Management, the Fish and Wildlife
    Service, and the Environmental Protection Agency.

    \18 Seattle Audubon Soc.  v.  Lyons, 871 F.  Supp.  1291 (W.D.  Wash.
    1994).

          DATA AND SYSTEMS ARE STILL
          LIMITED
    -------------------------------------------------------- Chapter 3:4.2

    Three acts or their implementing regulations establish data
    requirements for the Forest Service:  NFMA regulations require it to
    base its plans on comprehensive inventory data, NEPA regulations
    require it to consider high-quality information on the potential
    effects of a decision, and the Endangered Species Act (ESA) requires
    it to sufficiently understand species' habitat needs so that its
    decisions will ensure conservation of the species.  In a 1980 report
    on the Forest Service's then relatively new planning process to
    implement NFMA,\19 we stated that (1) without a complete inventory of
    natural resources, forest plans are bound to be inadequate and (2)
    the need for good data is greatest when resource conflicts are being
    identified and mitigated and when initial land-use and natural
    resource allocations are being made.

    Subsequent studies have shown that limitations in data and systems
    hindered the adequacy and implementation of many early forest plans.
    Thus, a decade later, we found that these deficiencies persist
    throughout the agency.  In 1994, for example, we reported that
    limitations in forestwide data and estimating techniques--which led
    to overestimating the size of the timber inventory in timber harvest
    areas--had contributed to lower-than-expected timber sales at four of
    the five forests included in our review.\20

    In the revisions it proposed to its planning regulations in April
    1995, the Forest Service conceded that "realistically, many forests
    do not have fully updated inventories at this time, so, regrettably,
    .  .  .  delays [of 2 years or more] must still be expected in some
    cases when forest plans are revised." Similarly, in its 1995 report,
    the Forest Service reengineering team, tasked with designing a new
    process for conducting project-level environmental analyses, noted
    that the agency still did not have a system of comparable
    environmental information that was useful and easily accessible to
    managers.

    Among its recommendations to streamline and improve the process for
    conducting project-level environmental analyses, the Forest Service
    reengineering team identified the need for a system of comparable
    environmental information that is useful and easily accessible to
    project officials.  However, over a year later, the Forest Service
    had not acted on this and other recommendations that could be
    implemented within the current statutory and regulatory framework.
    Instead, the agency combined the task force's recommendations for
    needed actions with proposals from other initiatives and developed an
    "action plan" to implement them.  The plan identified 13 major themes
    for fiscal year 1996, many of which were described as "high
    priority." However, none of the themes had been fully implemented
    throughout the agency at the end of the fiscal year, and the agency
    simply rolled them over to fiscal year 1997, again designating many
    as "high priority."

    According to the Forest Service, the adaptive learning model (see ch.
    2) developed to improve the timeliness of decision-making, which
    relies on having comprehensive inventory data, was successfully
    tested on the Wenatchee National Forest in Washington State.
    However, we observed that without adequate information, the model was
    difficult, if not impossible, to implement on the Lassen National
    Forest in northern California.  Here, Forest Service officials were
    responsible for renewing livestock grazing permits, but because they
    had not collected information on the condition of the land, they
    could not agree on or make informed decisions about the level of
    grazing to allow.  Although grazing had been permitted for a number
    of years, the forest had not monitored and evaluated the
    environmental effects of past grazing decisions.

    In addition, as we first reported in 1980, the failure of the Forest
    Service to base its decisions on sound information has resulted in
    continued legal challenges to its plans and projects.  These
    challenges have required the agency to delay, modify, or withdraw
    planned projects, thereby reducing the efficiency and effectiveness
    of its decision-making.

    --------------------
    \19 Changes in Public Land Management Required to Achieve
    Congressional Expectations (CED-80-82, July 16, 1980).

    \20 Forest Service:  Factors Affecting Timber Sales in Five National
    Forests (GAO/RCED-95-12, Oct.  28, 1994).

          PUBLIC PARTICIPATION IN
          DECISION-MAKING IS LIMITED
    -------------------------------------------------------- Chapter 3:4.3

    The public has expressed its desire to become more involved in the
    Forest Service's decision-making and has demonstrated its preference
    for presenting its concerns, positions, and supporting documentation
    during rather than after the agency's development of proposed forest
    plans and projects.  It has also signaled its intent to challenge
    decisions that it has not been involved in reaching.

    Both NEPA and NFMA create a positive duty on the part of the Forest
    Service to involve the public in its decision-making process.  The
    Forest Service's June 1990 Critique of Land Management Planning
    concluded that although public participation in the agency's
    decision-making process had increased, improvements were needed.
    Moreover, while many managers had done very well, others had involved
    the public only minimally in the process.  The document recommended
    that the agency find ways to inform and involve the public early and
    continuously in the process.

    In 1992, however, the Office of Technology Assessment (OTA) reported
    that the Forest Service had not used public input efficiently or
    effectively in its decision-making process.\21 According to OTA, much
    of the criticism was similar to that heard at least 20 years ago:
    The agency asks for public input, but the input does not affect final
    decisions.  In 1995, the interagency task force chaired by CEQ echoed
    this finding.  The task force reported that

         "the Forest Service dampens enthusiasm for effective public
         participation when it presents a management plan for a national
         forest to the public as a fait accompli.  Often, the preferred
         alternative is presented, giving the correct impression that the
         agency already knows what it wants to do and is requesting
         public input only pro forma."

    In the proposed revisions to its planning regulations, the Forest
    Service stated that although its success or failure in communicating
    with the public ultimately depends upon the people involved, certain
    expectations can be defined and minimum procedures established.  In
    August 1996, the Forest Service revised its Land and Resource
    Management Planning Handbook\22

    to give forest officials more flexibility and discretion in
    developing forest plans.  However, the agency retained its guidance
    and instructions limiting the public's participation in developing
    the plans.  The handbook directs forest officials not to release
    certain information critical to evaluating a forest plan until after
    the public comment period on the draft plan has closed and the final
    plan has been released.  This information includes (1) the agency's
    process for evaluating alternatives for managing the forest and
    arriving at the preferred one identified in the draft plan; (2) the
    physical, biological, social, and economic criteria used to evaluate
    the alternatives; and (3) the results of the evaluation.  Our work
    confirmed that forests comply with this requirement by using what is
    sometimes referred to as the "clay pigeon" approach, limiting the
    public primarily to reviewing and commenting on the preferred
    alternative in the draft plan.  Moreover, according to many members
    of the public with whom we spoke, the Forest Service does not value
    their input and/or does not involve them actively in its
    decision-making process.

    NFMA requires the Secretary of Agriculture to appoint advisory
    committees under the Federal Advisory Committee Act (FACA) if they
    are deemed "necessary to secure full information and advice." In an
    October 1995 report,\23 we stated that advisory committees
    established under FACA can be an effective tool for facilitating
    communication between federal and nonfederal parties.  Similarly, the
    1995 report by the interagency task force chaired by CEQ recommended
    that federal agencies consider making more extensive use of
    FACA-chartered advisory committees when seeking to collaborate
    closely with nonfederal parties on a regular and systematic basis.

    However, the Forest Service has identified FACA as a barrier to,
    rather than a tool for, effective public participation in its
    decision-making.  In the revisions to its planning regulations that
    it proposed in April 1995, the Forest Service states that
    interdisciplinary teams established to amend or revise forest plans
    will exclude the public.  According to the Forest Service, membership
    on the teams must be limited to agency and other federal personnel
    "primarily due to the Federal Advisory Committee Act, which imposes
    extensive requirements on the creation and use of committees that
    include non-Federal personnel for the purpose of advising Federal
    agencies."

    Inadequate public participation in decision-making can lead to
    appeals and litigation.  Although our October 1995 report on public
    participation in federal efforts to restore the Everglades showed
    that public involvement in federal land management decision-making
    should not be viewed as a panacea to legal challenges, most studies
    and reports agree that for both federal and nonfederal stakeholders,
    the benefits of working together cooperatively to resolve differences
    often outweigh the costs of early and continuous public involvement.

    --------------------
    \21 Forest Service Planning:  Accommodating Uses, Producing Outputs,
    and Sustaining Ecosystems, OTA-F-505 (Washington, D.C.:  Feb.  1992).

    \22 Forest Service handbooks are the principal source of specialized
    guidance and instruction for carrying out the direction in the Forest
    Service manual.  The manual contains legal authorities, objectives,
    policies, responsibilities, instructions, and guidance needed on a
    continuing basis by Forest Service line officers and primary staff in
    more than one unit to plan and execute assigned programs and
    activities.

    \23 Restoring the Everglades:  Public Participation in Federal
    Efforts (GAO/RCED-96-5, Oct.  24, 1995).

       RECENTLY ENACTED FEDERAL
       STATUTES ESTABLISH THE
       FRAMEWORK NECESSARY FOR
       STRENGTHENING ACCOUNTABILITY
    ---------------------------------------------------------- Chapter 3:5

    Landmark legislation enacted in the 1990s, if implemented
    successfully, will strengthen accountability within the Forest
    Service and improve the efficiency and effectiveness of its
    decision-making.  Specifically, the Chief Financial Officers Act of
    1990, as discussed previously, is intended to hold federal agencies
    more accountable for their expenditures of appropriated funds.  The
    Government Performance and Results Act of 1993 (GPRA) is designed to
    hold federal agencies more accountable for their performance.  The
    Clinger-Cohen Act of 1996 (formerly entitled, in part, the
    Information Technology Management Reform Act of 1996) and the
    Paperwork Reduction Act of 1995 are intended to hold them more
    accountable for the adequacy of their information systems and data.

          THE GOVERNMENT PERFORMANCE
          AND RESULTS ACT
    -------------------------------------------------------- Chapter 3:5.1

    GPRA is the primary legislative framework through which federal
    agencies will be required to set strategic goals, measure
    performance, and report on the degree to which goals have been met.
    It requires each federal agency to develop, no later than September
    30, 1997, a strategic plan that covers a period of at least 5 years.
    Each plan must include the agency's mission statement; identify the
    agency's long-term strategic goals; and describe how the agency
    intends to achieve these goals through its activities and through its
    human, capital, information, and other resources.  Under GPRA,
    strategic plans are the starting point for agencies to set annual
    goals for programs and to measure the performance of the programs in
    achieving those goals.

    Starting with fiscal year 1999, the Forest Service and other federal
    agencies are required to produce annual performance plans containing
    (1) annual performance goals for gauging the progress made toward
    achieving longer-term strategic goals and (2) performance measures
    for assessing the progress made toward achieving annual performance
    goals.  By March 31, 2000, federal agencies are to submit annual
    program performance reports for fiscal year 1999.  (See fig.  3.1.)

       Figure 3.1:  Implementing GPRA:
       Key Steps and Critical
       Practices

       (See figure in printed
       edition.)

          THE CLINGER-COHEN ACT AND
          THE PAPERWORK REDUCTION ACT
    -------------------------------------------------------- Chapter 3:5.2

    Under the Clinger-Cohen Act of 1996, the Forest Service and other
    federal agencies must establish goals, measure performance, and
    report in their annual budget submissions to the Congress on how well
    their information technologies are supporting their mission-related
    programs.  This act also calls for federal agencies to "benchmark"
    their information technology management processes against comparable
    processes of public or private-sector organizations.  Agencies are to
    revise or reengineer their processes, as appropriate, before making
    investments in information technology.

    A related statute, the Paperwork Reduction Act of 1995, also provides
    for improving the productivity, efficiency, and effectiveness of
    federal operations, including those of the Forest Service, through
    better management of information resources to accomplish the missions
    and improve the performance of federal agencies.  The act stipulates
    that agency officials are responsible and accountable for the
    information resources supporting their programs.  Specifically,
    agency program officials, in consultation with their chief
    information officer and chief financial officer (or comparable
    official), are to define their program's information needs and
    develop strategies, systems, and capabilities to meet these needs.
    They are also required to develop a plan to meet their information
    needs that contains goals and methods for measuring progress toward
    achieving them.  In addition, agencies are to maintain ongoing
    processes to ensure that information management is integrated with
    organizational planning, budget, financial management, and program
    decisions.  The Director of the Office of Management and Budget,
    within the Executive Office of the President, is to report annually
    to the Congress on the agencies' progress in achieving their
    information management goals.

       CONCLUSIONS
    ---------------------------------------------------------- Chapter 3:6

    If the Forest Service is to develop forest plans and reach
    project-level decisions more efficiently and implement the plans more
    effectively, it will need to be held sufficiently accountable for its
    expenditures and performance.  Accountability is the price that
    managers at every organizational level within the agency must pay for
    the freedom to make choices.  The data and financial controls and
    systems required by the Chief Financial Officers Act; the performance
    goals, measures, and reports required by GPRA; and the information
    resources and technology goals, measures, and reports required by the
    Clinger-Cohen Act and the Paperwork Reduction Act are, in essence,
    the currency of that accountability.  However, to ensure the full and
    effective implementation of these legislative mandates, sustained
    management attention within the Forest Service and sustained
    oversight by the Congress will be required.

    AGREEMENT NEEDS TO BE REACHED ON
    HOW TO RESOLVE CONFLICTS AMONG
    COMPETING USES
    ============================================================ Chapter 4

    The Government Performance and Results Act of 1993 (GPRA), if
    implemented successfully, will strengthen accountability for
    performance and results within the Forest Service and improve the
    efficiency and effectiveness of its decision-making.  Successful
    implementation of the act's requirements is contingent on
    establishing long-term strategic goals that are based on clearly
    defined mission priorities.  However, agreement does not exist on the
    Forest Service's long-term strategic goals.  This lack of agreement
    is the result of a more fundamental disagreement, both inside and
    outside the Forest Service, over which uses to emphasize under the
    agency's broad multiple-use and sustained-yield mandate and how best
    to ensure the long-term sustainability of these uses.

    In developing the strategic plans that they are required by GPRA to
    submit to the Congress by September 30, 1997, federal agencies are to
    consider the views of the Congress and other stakeholders.  To ensure
    that the agencies do so, the act requires them to consult with the
    Congress and solicit the views of stakeholders.\1 This process may
    entail identifying legislative changes that are needed to clarify or
    modify the Congress's intent and expectations or to address differing
    conditions and/or citizens' needs that have evolved since the
    statutory requirements were established.\2 Such a consultation would
    create an opportunity for the Forest Service to gain a clearer
    understanding of how it is to resolve conflicts or make choices among
    competing uses on its lands.  This understanding would, in turn,
    provide the agency with a basis for establishing long-term strategic
    goals, as well as the performance goals and measures that are linked
    to them.

    --------------------
    \1 Managing for Results:  Enhancing the Usefulness of GPRA
    Consultations Between the Executive Branch and Congress
    (GAO/T-GGD-97-56, Mar.  10, 1997).

    \2 Executive Guide:  Effectively Implementing the Government
    Performance and Results Act (GAO/GGD-96-118, June 1996).

       THE FOREST SERVICE HAS SHIFTED
       ITS EMPHASIS FROM TIMBER TO
       WILDLIFE AND FISH
    ---------------------------------------------------------- Chapter 4:1

    The Forest Service's October 1995 draft long-term strategic plan,
    prepared under the Forest and Rangeland Renewable Resources Planning
    Act of 1974 (RPA) (see app.  I),\3 identified four new goals:  (1)
    protecting ecosystems\4

    by ensuring their health and diversity while meeting people's needs;
    (2) restoring deteriorated ecosystems to improve the likelihood that
    biological diversity, long-term sustainability, and future options
    are maintained; (3) providing multiple benefits to meet people's
    needs for uses, values, products, and services within the
    capabilities of ecosystems; and (4) ensuring organizational
    effectiveness by creating and maintaining a multidisciplinary and
    multicultural workforce, respecting expertise and professionalism,
    and empowering people to carry out the agency's mission while holding
    them accountable for achieving negotiated objectives.  The agency
    also plans to establish these four goals as its long-term strategic
    goals under GPRA.\5

    The three goals relating to ecosystems reflect the ongoing shift in
    emphasis under the Forest Service's broad multiple-use and
    sustained-yield mandate from consumption (primarily producing timber)
    to conservation (primarily sustaining wildlife and fish).  This shift
    is taking place in reaction to requirements in planning and
    environmental laws and their judicial interpretations--reflecting
    changing public values and concerns--together with social,
    ecological, and other factors.

    The increasing emphasis on sustaining wildlife and fish conflicts
    with the older emphasis on producing timber and other commodities and
    underlies the Forest Service's inability to achieve the goals and
    objectives for timber production set forth in many of the first
    forest plans.  In addition, this attention to sustaining wildlife and
    fish will likely constrain future uses of the national forests, such
    as recreation.  The demand for recreation is expected to grow and may
    increasingly conflict with both sustaining wildlife and fish and
    producing timber on Forest Service lands.

    --------------------
    \3 The Forest Service Program for Forest and Rangeland Resources:  A
    Long-Term Strategic Plan, Draft 1995 RPA Program, USDA, Forest
    Service, Washington Office (Oct.  16, 1995.)

    \4 One definition of an ecosystem is a distinct ecological unit that
    is formed when interdependent communities of plants and animals,
    which can include humans, interact with their physical environment
    (soil, water, and air).

    \5 See Concerning Implementation of the Government Performance and
    Results Act (GPRA) in the USDA Forest Service, statement by the
    Forest Service's Acting Deputy Chief, Programs and Legislation,
    before the Subcommittee on Management, Information, and Technology,
    House Committee on Government Reform and Oversight (Mar.  10, 1997).

          THE FIRST FOREST PLANS
          EMPHASIZED TIMBER PRODUCTION
    -------------------------------------------------------- Chapter 4:1.1

    The Organic Administration Act of 1897 and the Multiple-Use
    Sustained-Yield Act of 1960, which guide the management of the
    nation's forests, provide little direction for the Forest Service in
    resolving conflicts among competing multiple uses on its lands
    (outdoor recreation, rangeland, timber, watersheds and water flows,
    wilderness, and wildlife and fish) or between current uses and future
    uses (sustained yield).  The definition of multiple use contains no
    specific goals for any particular use and only a general
    environmental protection requirement (i.e., management is not to
    impair the long-term productivity of the land).  As a result, the
    emphasis that the Forest Service gives to the various uses under its
    broad multiple-use and sustained-yield mandate responds to factors
    supplementing these acts, such as requirements and incentives in
    other laws, congressional expectations, and national and local values
    and concerns.

    From the end of World War II through the late 1980s, the Forest
    Service emphasized timber production.  Hence, the agency emphasized
    timber production in many of its first forest plans.  Figure 4.1
    shows the volume of timber sold from Forest Service lands between
    1950 and 1994.

       Figure 4.1:  Volume of Timber
       Sold From Forest Service Lands,
       1950-94

       (See figure in printed
       edition.)

    Note:  Volume is in billions of board feet.  A board foot is a
    measure of wood volume equal to a board 1 foot long by 1 foot wide by
    1 inch thick.

    Source:  Forest Service.

    Requirements and incentives in laws supplementing the acts that guide
    the management of the nation's forests encouraged the Forest Service
    to produce high levels of timber on its lands.  For example, the
    Knutson-Vandenberg Act of 1930, as amended in 1976, allows the
    national forests to retain a portion of their timber sale receipts to
    help fund the reforestation of harvested areas, as well as the
    protection or improvement of nontimber resources, such as fish and
    wildlife habitat, and of recreation areas and facilities.  The Forest
    Service maintains the Knutson-Vandenberg Trust Fund for this purpose.
    The agency was also mindful of the increased demand for timber from
    federal lands to meet postwar housing construction needs and to
    replace the supply of timber from depleted industrial lands.  In
    addition, in reports accompanying annual appropriation acts, the
    Congress set "target" levels of timber to be harvested and
    appropriated money for the administration of timber sales with the
    expectation that the targets would be met.

    In addition to these incentives and expectations, the linear computer
    programming models used by the Forest Service to estimate forest plan
    objectives focused on timber and were not able to account accurately
    for interactions with other uses.  Sometimes, the goals for timber
    were arbitrarily increased by Agriculture's Under Secretary for
    Natural Resources, or inputs to the models were adjusted to produce
    the desired results.  For example, the Forest Service did not allow
    the timber-offering goal on the Flathead National Forest in
    northwestern Montana to be inconsistent with the harvest levels of
    the preceding few years.  To project this goal, the Forest Service
    modified the locations and methods of timber harvesting used in the
    models without identifying the resulting environmental effects.\6

    Some of the first forest plans also did not adequately (1) consider
    species listed as endangered or threatened under the Endangered
    Species Act (ESA) and/or (2) anticipate the listing of candidate
    species\7 or the designation of habitat critical to the survival of
    listed species.  For example, plans for national forests in Arizona
    and New Mexico included decisions to move to more even-age timber
    harvesting\8 and to harvest on steep slopes.  These decisions would
    have adversely affected the habitat of the Mexican spotted owl, which
    was, at the time, designated by the Forest Service as a sensitive
    species\9 under regulations implementing the National Forest
    Management Act (NFMA) and became a candidate for listing under ESA
    shortly after the plans were approved.  The subsequent listing of the
    owl was a primary reason why the forests did not achieve the plans'
    objectives.  Furthermore, although the needs of wildlife were
    considered in developing the first forest plans, in some cases,
    Forest Service managers chose to emphasize timber production and
    other uses, such as livestock grazing, that conflicted with
    sustaining wildlife and fish.\10

    --------------------
    \6 Forest Service:  The Flathead National Forest Cannot Meet Its
    Timber Goal (GAO/RCED-91-124, May 10, 1991).

    \7 Candidate species are recognized by the Fish and Wildlife Service
    and/or the National Marine Fisheries Service as being vulnerable
    enough to support proposals that would list them as endangered or
    threatened.  See Endangered Species Act:  Types and Number of
    Implementing Actions (GAO/RCED-92-131BR, May 8, 1992).

    \8 Even-age timber harvesting is a method that involves removing most
    or all of the trees from the timber-harvesting site at one time.

    \9 Sensitive species are those for which there is some evidence of
    risk, but that are not sufficiently imperiled to be listed as
    threatened or endangered under the Endangered Species Act.

    \10 Public Land Management:  Attention to Wildlife Is Limited
    (GAO/RCED-91-64, Mar.  7, 1991).

          EMPHASIS HAS INCREASINGLY
          SHIFTED TO SUSTAINING
          WILDLIFE AND FISH
    -------------------------------------------------------- Chapter 4:1.2

    During the last 10 years, the Forest Service has increasingly shifted
    its emphasis from producing timber to sustaining wildlife and fish
    under its broad multiple-use and sustained-yield mandate.  This shift
    is taking place in response to requirements in planning and
    environmental laws--enacted primarily during the 1960s and 1970s--and
    their evolving judicial interpretations.  In particular, section 7 of
    ESA 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.\11 When proposing a
    project, the Forest Service bears the burden of demonstrating that
    its actions will not likely jeopardize listed species.

    Social, ecological, and other factors have also contributed to the
    shift in emphasis.  These factors include (1) an increasing knowledge
    of the importance of naturally functioning systems--such as
    watersheds, airsheds, soils, and vegetative and animal
    communities--to the long-term sustainability of other forest uses,
    including timber production;\12 (2) an increasing recognition that
    past Forest Service management decisions have led to degraded aquatic
    habitats, declining populations of some wildlife species, and
    increased forest health problems;\13 (3) an increasing number of
    environmental restrictions that have necessitated the use of more
    costly and time-consuming timber-harvesting methods;\14 and (4)
    activities occurring outside the national forests, such as timber
    harvesting on state and private lands, whose effects the agency must
    assess in deciding which uses to emphasize on its lands.

    For example, on June 4, 1992, the Chief of the Forest Service
    announced a new policy of multiple-use ecosystem management on the
    national forests and grasslands.  According to the Chief, the
    announcement was based on the results of experiments to develop more
    environmentally sensitive ways to manage the forests.  In conjunction
    with this new ecosystem management policy, the Forest Service
    announced plans to reduce the amount of timber harvested by
    clearcutting\15 by as much as 70 percent from fiscal year 1988
    levels.

    In addition, the acreage available for timber production has declined
    steadily.  Portions of the national forests have been set aside by
    the Congress or administratively withdrawn for conservation--as
    wilderness, wild and scenic rivers, national monuments, and
    recreation.  In 1964, less than 9 percent (16 million acres) of
    national forest land was managed for conservation.  By 1994, this
    figure had increased to 26 percent (almost 50 million acres).\16 (See
    fig.  4.2.)

       Figure 4.2:  National Forest
       Lands Withdrawn for
       Conservation Purposes

       (See figure in printed
       edition.)

    Most of the federal acreage that has been set aside for conservation
    purposes is located in 12 western states.\17 In western Washington
    State, western Oregon, and northern California, where 24.5 million
    acres of federal land were available for commercial timber harvest,
    about 11.4 million acres, or 47 percent of the available acreage,
    have been set aside by the Congress or administratively withdrawn
    under the original forest plans for such uses as wilderness, wild and
    scenic rivers, national monuments, and recreation.

    Other environmental requirements have further reduced the amount of
    federal land available for timber production.  For example, 7.6
    million acres (31 percent) of these federal lands that were available
    for commercial timber harvesting have been set aside or withdrawn as
    habitat for species that live in old-growth forests, including the
    threatened northern spotted owl, or as riparian reserves to protect
    watersheds.  To protect the forests' health, only limited timber
    harvesting and salvage timber sales are allowed in some of these
    areas.

    In total, 77 percent of the 24.5 million acres of these federal lands
    that were available for commercial timber harvesting have been set
    aside or withdrawn, primarily for conservation or to meet
    environmental requirements.  In addition, requirements for
    maintaining biological diversity under NFMA--as well as for meeting
    standards for air and water quality under the Clean Air and Clean
    Water acts, respectively--may limit the timing, location, and amount
    of harvesting that can occur.  Moreover, harvests from these lands
    could be further reduced by plans to protect threatened and
    endangered salmon.\18

    --------------------
    \11 TVA v.  Hill, 437 U.S.  153, 185 (1978).

    \12 Ecosystem Management:  Additional Actions Needed to Adequately
    Test a Promising Approach (GAO/RCED-94-111, Aug.  16, 1994).

    \13 See, for example, Federal Fire Management:  Limited Progress in
    Restarting the Prescribed Fire Program (GAO/RCED-91-42, Dec.  5,
    1990).

    \14 Forest Service:  Factors Affecting Timber Sales in Five National
    Forests (GAO/RCED-95-12, Oct.  28, 1994).

    \15 Clearcutting is a harvesting method that involves removing all of
    the trees from a timber-harvesting site at one time.

    \16 Land Ownership:  Information on the Acreage, Management, and Use
    of Federal and Other Lands (GAO/RCED-96-40, Mar.  13, 1996).

    \17 The 12 western states are Alaska, Arizona, California, Colorado,
    Idaho, Montana, Nevada, New Mexico, Oregon, Utah, Washington, and
    Wyoming.

    \18 Private Timberlands:  Private Timber Harvests Not Likely to
    Replace Declining Federal Harvests (GAO/RCED-95-51, Feb.  16, 1995).

          SUSTAINING WILDLIFE AND FISH
          CONSTRAINS OTHER USES
    -------------------------------------------------------- Chapter 4:1.3

    The Forest Service is increasingly unable to avoid, resolve, or
    mitigate conflicts among competing uses on national forests by
    separating them among areas and over time.  Therefore, while
    sustaining wildlife and fish may be important to the long-term
    sustainability of other forest uses, including timber production, the
    increasing emphasis on protecting and restoring ecosystems and on
    sustaining wildlife and fish (1) conflicts with the older emphasis on
    producing timber and underlies the Forest Service's inability to
    achieve the goals and objectives for timber production set forth in
    many of the first forest plans and (2) will likely constrain future
    uses of the national forests, such as recreational uses.

    The volume of timber sold from Forest Service lands decreased from a
    peak of over 11.3 billion board feet in 1988 to 3.1 billion board
    feet in 1994, a decrease of about 73 percent.  (See fig.  4.1.)
    Timber sold from Forest Service lands in western Washington, western
    Oregon, and northern California declined from 4.3 billion board feet
    in 1989 to 0.9 billion board feet in 1994, a decrease of about 80
    percent.

    At the forest level, the Forest Service approved the forest plans for
    the Deschutes and Mt.  Hood national forests in Oregon and the
    Gifford Pinchot National Forest in Washington in 1991; however, the
    volume of timber sold during fiscal years 1991 through 1993 (the
    first 3 fiscal years covered by the plans) fell short of the plans'
    timber goals by about 83 percent.  (See table 2.1.) Similarly, at the
    Chattahoochee-Oconee National Forest in Georgia, officials estimated
    that the costs per million board feet to prepare timber sales and
    administer harvests rose by approximately 36 percent between 1988 and
    1993, when the agency began to increase its use of other, more costly
    and time-consuming harvesting methods to comply with requirements in
    environmental laws and regulations.  As a result, less timber was
    prepared for sale than had been planned.  (See table 2.1.)\19

    In addition, increasing attention to sustaining wildlife and fish
    will likely constrain future uses of the national forests.  For
    example, the demand for recreation is expected to grow and may
    increasingly conflict with both sustaining wildlife and fish and
    producing timber on Forest Service lands.

    According to the Forest Service, the American public has increased
    its recreational use of the national forests substantially, from
    about 25 million visitor days in 1950 to nearly 350 million visitor
    days in 1995.  (See fig.  4.3.) This demand is expected to increase
    steadily over the next 50 years and will require the agency to spend
    more time and resources reconciling the demands for recreation and
    for sustaining wildlife and fish.\20

       Figure 4.3:  Visitor Days in
       National Forests, 1950-94

       (See figure in printed
       edition.)

    Note:  Data through 1964 are in "visits." A visit equals one entry
    into a national forest.  Data after 1964 are in "visitor days." A
    visitor day equals a 12-hour visit.  For example, three people
    visiting a national forest for 4 hours each would equal one visitor
    day.  In 1965, a visit averaged 0.83 visitor days.

    Source:  Forest Service.

    For example, officials at the Chequamegon National Forest in
    Wisconsin told us that recreational snowmobiling and
    all-terrain-vehicle use are rapidly increasing on the forest, posing
    ever more serious conflicts with the agency's efforts to maintain or
    restore wildlife and fish habitat.  The officials said they could not
    have anticipated this phenomenon when the forest plan was approved in
    1986, and they anticipate that snowmobiling and all-terrain-vehicle
    use in the forest will likely have to be constrained in order to
    sustain wildlife and fish.

    Additionally, officials at the Nantahala-Pisgah National Forest in
    North Carolina told us that a very significant increase in rafting on
    rivers in their forest and in other forests adjacent to it has forced
    the agency to restrict and closely monitor this activity to prevent
    resulting stream bank erosion that damages fish and riparian habitat.
    Similarly, consideration of the potential effects of artificial
    snow-making on the levels and quality of the lakewater needed for
    aquatic habitat in the White Mountain National Forest in New
    Hampshire has limited the expansion of ski facilities on the forest.

    The demand for habitat to sustain wildlife and fish is expected to
    grow on Forest Service lands, in part because the Department of the
    Interior has adopted a policy that increases the federal land
    management agencies' ultimate responsibility for protecting
    threatened and endangered species.  Specifically, under an August
    1994 "no surprise policy," the Fish and Wildlife Service agreed, in
    exchange for commitments by nonfederal landowners to adopt properly
    functioning habitat conservation plans deemed adequate by Interior to
    protect threatened or endangered species, that (1) it would not ask
    for more land or mitigation funding from the private landowners or
    state or local governments even if a species protected by such a plan
    continued to decline and (2) the subsequent listing of a species as
    endangered or threatened under ESA would not result in additional
    mitigation requirements.  Rather, any additional mitigation deemed
    necessary to protect a listed species covered by a habitat
    conservation plan must first be accomplished on federal lands.  Thus,
    some Forest Service officials believe that the national forests will
    assume a growing proportion of the responsibility for protecting
    wildlife and fish and that endangered and threatened species and
    their habitats will increasingly be concentrated on federal lands.

    --------------------
    \19 Forest Service:  Factors Affecting Timber Sales in Five National
    Forests (GAO/RCED-95-12, Oct.  28, 1994).

    \20 The Forest Service Program for Forest and Rangeland Resources:  A
    Long-Term Strategic Plan, Draft 1995 RPA Program, USDA, Forest
    Service, Washington Office (Oct.  16, 1995.)

       AGREEMENT DOES NOT EXIST ON
       WHICH USES THE FOREST SERVICE
       SHOULD EMPHASIZE ON ITS LANDS
    ---------------------------------------------------------- Chapter 4:2

    While the Forest Service continues to reduce its emphasis on
    consumption and increase its emphasis on conservation, the Congress
    has never explicitly accepted this shift in emphasis or acknowledged
    its effects on the availability of other uses on the national
    forests.  Disagreement over the Forest Service's priorities, both
    inside and outside the agency, is manifested in conflicting
    legislative incentives and congressional expectations, differences in
    the beliefs of Forest Service personnel, and legal challenges to the
    agency's plans and projects.

    One result of the internal and external disagreement over the Forest
    Service's priorities is that budgeting decisions reflected in final
    appropriations change the priorities of the forest plans during their
    implementation.\21 In a 1980 report,\22 we noted that the balanced
    use and development of resources on national forests had been
    hampered by a continuing budgetary emphasis on timber production in
    the Forest Service.  As a result, other resources, such as wildlife
    and fish, had not received needed management attention.  A decade
    later, the Forest Service stated that during the yearly budget review
    by the Secretary of Agriculture, the Office of Management and Budget,
    and the Congress, money is added to or subtracted from budget line
    items with little or no recognition that the items are related.
    Consequently, (1) the congressional appropriation and accompanying
    direction can comprise a very different mix of funding than is called
    for by the forest plans and (2) "there is no point in the public
    investing time negotiating plans if Congress acts to set bounds on
    planning--through mandated timber sale targets, for example."\23 A
    report issued by the Office of Technology Assessment (OTA) in 1992\24
    reaffirmed this concern, noting that "resulting appropriations bear
    little resemblance to the integrated management presented in the
    forest plans."

    --------------------
    \21 Synthesis of the Critique of Land Management Planning, Vol.  1,
    Forest Service (FS-452, June 1990).

    \22 Changes in Public Land Management Required to Achieve
    Congressional Expectations (CED-80-82, July 16, 1980).

    \23 Critique of Land Management Planning, Vol.  2, National Forest
    Planning:  Searching for a Common Vision, Forest Service, (FS-453,
    June 1990).

    \24 Forest Service Planning:  Accommodating Uses, Producing Outputs,
    and Sustaining Ecosystems, OTA-F-505 (Washington, D.C.:  Feb.  1992).

          THE CONGRESS HAS SENT MIXED
          MESSAGES
    -------------------------------------------------------- Chapter 4:2.1

    The requirements in planning and environmental laws--enacted
    primarily during the 1960s and 1970s--have directed the Forest
    Service to place increasing emphasis on sustaining wildlife and fish.
    However, legislative incentives emphasizing timber production
    persist.

    Despite the increasing emphasis on conservation in recent
    legislation, the Forest Service still relies on timber production to
    fund many of its activities.  A substantial portion of the receipts
    from timber sales are distributed into a number of funds and accounts
    that the agency uses to finance various activities.  According to
    OTA, these receipts accounted for nearly one-third of the Forest
    Service's budget annually.  These receipts, coupled with appropriated
    funds linked primarily to timber production, constitute most of the
    agency's operating funds.  Therefore, many forest managers have the
    opportunity to increase their own budgets by increasing timber
    sales.\25

    For example, the Knutson-Vandenberg Act of 1930, as amended,
    authorizes the use of timber sale receipts not only to reforest
    harvested areas but also to improve and protect the land's future
    productivity and help fund regional and headquarters office expenses.
    The Knutson-Vandenberg Trust Fund received about 25 percent of the
    total timber receipts during fiscal years 1992 through 1994.\26 In
    addition, NFMA creates incentives for salvage sales through the
    Salvage Sale Fund, a permanent appropriation.  The Forest Service
    replenishes this fund through salvage sale receipts.  These receipts
    are then used to prepare and administer future salvage sales and to
    pay for designing, engineering, and supervising the construction of
    roads associated with such sales.  The Salvage Sale Fund received
    about 18 percent of the total timber sale receipts during fiscal
    years 1992 through 1994.\27 An October 1996 report\28 by an
    interagency team states that, because salvage sales can be more
    easily funded than other forest health activities, they are sometimes
    selected over other activities that might be more appropriate in
    particular circumstances.

    The Congress has taken other actions that have emphasized timber
    production in the short term.  It has (1) limited the judicial review
    of challenges to certain Forest Service decisions, usually timber
    sales; (2) suspended the application of some environmental
    requirements; and/or (3) mandated increases in the amount of timber
    to be offered for sale.  For example, section 2001 of Public Law
    104-19--the Emergency Salvage Timber Sale Program, known as the
    "salvage rider" or the "timber rider"--went far beyond procedurally
    expediting salvage sales to improve the forests' health and allowed
    the sale of both green and salvage timber from national forests.
    This rider exempted all such sales from administrative appeals,
    limited judicial review, and deemed the sales to be in compliance
    with environmental laws.

    According to OTA's 1992 report, congressional efforts to change the
    judicial review process "seem to be attempts to resolve substantive
    issues without appearing to take sides." The report concludes that
    "such changes are unlikely to improve forest planning or plan
    implementation, or reduce conflict over national forest management."
    Moreover, increasing the short-term production of timber may require
    the Forest Service to amend or revise its forest plans to take into
    account the environmental effects of the sales.\29

    As a result, the Congress continues to send a mixed message to the
    Forest Service concerning which uses to emphasize and how to resolve
    conflicts among competing uses on its lands.  According to an
    analysis that grew out of a 1993 symposium sponsored by the Society
    of American Foresters on change in the Forest Service,\30 the
    movement toward wildlife and fish was mandated by the Congress
    through the National Environmental Policy Act and NFMA.  However,
    according to the analysis, "Ironically, Congress can serve as a
    primary obstacle to the Forest Service's implementation of the very
    laws the Congress has enacted for it by setting unrealistic harvest
    levels and not having appropriations in sync with the goals set
    through the RPA and NFMA planning processes that Congress itself
    mandated."

    --------------------
    \25 Forest Service Management:  Issues to Be Considered in Developing
    a New Stewardship Strategy (GAO/T-RCED-94-116, Feb.  1, 1994).

    \26 Forest Service:  Distribution of Timber Sales Receipts, Fiscal
    Years 1992-94 (GAO/RCED-95-237FS, Sept.  8, 1995).

    \27 See footnote 20.

    \28 Interagency Salvage Program Review, U.S.  Department of Commerce,
    National Oceanic and Atmospheric Administration, National Marine
    Fisheries Service (Silver Spring, Maryland:  Oct.  8, 1996).  The
    agencies were the National Marine Fisheries Service, the Forest
    Service, the Bureau of Land Management, the Fish and Wildlife
    Service, and the Environmental Protection Agency.

    \29 The "Timber Rider":  Section 2001 of the Rescissions Act (CRS
    Report for Congress, 96-163A, Feb.  22, 1996).

    \30 "Change in the United States Department of Agriculture Forest
    Service and Its Consequences for National Forest Policy," Policy
    Studies Journal, Vol.  23, No.  2 (1995).

          PRIORITIES WITHIN THE FOREST
          SERVICE ARE MIXED
    -------------------------------------------------------- Chapter 4:2.2

    The mixed message from the Congress about which uses to emphasize and
    how to resolve conflicts among competing uses filters down through
    the Forest Service.  For example, according to another analysis
    prepared in response to the 1993 symposium on change in the Forest
    Service, over 20 percent of the agency's personnel believe that
    timber still should be the most important forest use and 60 percent
    believe that the agency still considers timber to be the most
    important forest use.  Additionally, a 1994 survey of Forest Service
    personnel stated that nearly half did not believe that the current
    levels of uses in their forests could be sustained for 100 years, and
    about 70 percent said that the agency's target-driven behavior does
    not match its stated policy.\31 Similarly, the interagency team that
    reviewed the "salvage rider" timber program observed in 1996 that
    Forest Service personnel implementing the program fell into three
    groups:  Some focused only on achieving additional salvage timber
    volume, others focused only on protecting forest ecosystems, while
    still others focused on balancing the two objectives.

    During field visits, we found that timber production still often
    receives more emphasis than other uses and still plays a significant
    role in individual performance management, career development, and
    pay and promotion.  As one district ranger said, "of course, all
    targets are important, but everyone understands which one is
    considered by the agency to be the most important--timber."

    In August 1996, the Forest Service amended its forest planning and
    timber management handbooks to give forest officials more flexibility
    and discretion in developing forest plan alternatives.  However, the
    handbooks continue to emphasize timber, prescribing that the plans be
    developed around combinations of small geographic units called
    "analysis areas," which are to be constructed from data on timber
    stands and categories rather than from information on all forest
    uses.  In our visits to national forests, agency officials told us
    that developing plans around analysis areas had contributed to an
    emphasis on timber in the original plans and an inability to account
    accurately for timber's interactions with other uses.

    --------------------
    \31 Policies and Mythologies of the U.S.  Forest Service:  A
    Conversation With Employees, Research Report for the Director,
    Pacific Northwest Experiment Station and Chief, USDA Forest Service,
    University of Washington, College of Forest Resources (Seattle,
    Washington:  Feb.  1994).

          STAKEHOLDERS' EXPECTATIONS
          ARE MIXED
    -------------------------------------------------------- Chapter 4:2.3

    Supporters or former beneficiaries of the Forest Service's historical
    emphasis on timber production may view the agency's increasing
    emphasis on sustaining wildlife and fish as a constraint to, rather
    than a goal of, decision-making.  Others who believe that sustaining
    wildlife and fish needs to be emphasized may think that the agency is
    not moving quickly enough to implement the shift in emphasis.
    Without agreement on how the Forest Service is to resolve conflicts
    or make choices among competing uses on its lands, proponents of both
    positions have looked to the courts to decide which uses the agency
    should emphasize.

    Our prior work has shown that dissatisfaction with an agency's
    process for public involvement often cannot be dissociated from
    dissatisfaction with the outcome of the process.\32 Thus, it is
    difficult to determine how many of the over 1,200 administrative
    appeals and 20 to 30 new lawsuits contesting the Forest Service's
    decisions each year can be attributed to the lack of agreement on the
    Forest Service's priorities.  However, parties opposed to the
    emphasis given to a particular use can cause the Forest Service to
    delay, alter, or withdraw projects by availing themselves of the
    opportunities for administrative appeal and judicial review that are
    provided by statute or regulation.

    --------------------
    \32 Restoring the Everglades:  Public Participation in Federal
    Efforts (GAO/RCED-96-5, Oct.  24, 1995).

       THE GOVERNMENT PERFORMANCE AND
       RESULTS ACT PROVIDES A
       FRAMEWORK TO REACH AGREEMENT
    ---------------------------------------------------------- Chapter 4:3

    GPRA requires federal agencies, when developing their strategic
    plans, to consult with the Congress and solicit the views of
    stakeholders.  Full agreement among stakeholders on all aspects of an
    agency's efforts is relatively uncommon because stakeholders'
    interests can differ often and significantly.  However, to be
    successful, such a consultation between the Forest Service and the
    Congress would need to focus on the issues of long-term
    sustainability and conflict resolution rather than solely on
    balancing multiple uses in the short term.

          EFFORTS TO REACH AGREEMENT
          ON RESOLVING CONFLICTS HAVE
          NOT BEEN SUCCESSFUL
    -------------------------------------------------------- Chapter 4:3.1

    Recently, several efforts have been made to reach agreement on how to
    resolve conflicts.  However, these efforts have merely reaffirmed the
    agency's broad multiple-use mission rather than provided the Forest
    Service with clearer guidance for resolving conflicts or making
    choices among competing uses on its lands.

    For example, both the Chief of the Forest Service and Agriculture's
    Under Secretary for Natural Resources and Environment expressed their
    hope that the Seventh American Forest Congress would produce new
    insights and valuable ideas to guide the Forest Service into the next
    century.  Toward this end, the Forest Congress convened about 1,100
    federal, state, local, and tribal officials and representatives from
    environmental, professional forestry, industry, and recreation groups
    in Washington, D.C., in February 1996.  The focus of the convention
    was on identifying a common vision for America's forests and the
    principles needed to guide the country toward this vision.

    While the convention reaffirmed the Forest Service's broad
    multiple-use mission, it did not tackle the tough issue of how the
    Forest Service is to resolve conflicts or make choices among
    competing uses on its lands.  For example, participants at the
    convention were allowed to treat each principle as a "stand-alone
    point." As a result, they could agree with conflicting principles.
    For instance, they could recognize the special importance of
    old-growth forests while agreeing that the remaining publicly owned
    old-growth forests should not be protected for future generations.\33

    Because the participants were never required to make hard choices
    among competing uses, disparate groups--from supporters of timber
    production to advocates of old-growth preservation--could support the
    principle of multiple uses on national forests without addressing or
    resolving the inherent conflicts it involves.

    --------------------
    \33 Final Report, Seventh American Forest Congress (Apr.  2, 1996).

          CONSULTATION SHOULD RESULT
          IN AGREEMENT ON LONG-TERM
          STRATEGIC GOALS
    -------------------------------------------------------- Chapter 4:3.2

    Successful consultation between the Forest Service and the Congress
    would lead to agreement on the agency's long-term strategic goals.
    If such agreement is to occur, the Forest Service will need to
    clearly outline the logic and thinking behind its increasing emphasis
    on sustaining wildlife and fish under its broad multiple-use and
    sustained-yield mandate and explain how it would resolve conflicts or
    make choices among competing uses on its lands under its proposed
    long-term strategic goals.  Toward this end, both the Forest
    Service's Chief and Agriculture's Under Secretary for Natural
    Resources and Environment have testified that the National Forest
    System's management now emphasizes the maintenance of ecosystems'
    health to sustain the production of all goods and services derived
    from national forests.  According to them, management activities such
    as timber sales serve as "tools" for improving the forests' health.
    For example, salvage timber sales are sometimes used to improve a
    forest's health.

          PERFORMANCE GOALS AND
          MEASURES WOULD BE BASED ON
          LONG-TERM STRATEGIC GOALS
    -------------------------------------------------------- Chapter 4:3.3

    In a February 25, 1997, letter to the Director of the Office of
    Management and Budget, the Speaker of the House, the House Majority
    Leader, the Senate Majority Leader, and key committee chairmen from
    both the House and the Senate set forth their expectations for
    agencies' consultations with the Congress under GPRA.  In the letter,
    they stated that the consultation process should result in a
    reasonable degree of agreement on the performance measures that will
    be used to gauge success.  If the four goals in the Forest Service's
    October 1995 draft long-term strategic plan remain unchanged, the
    Congress could expect to see performance goals and measures based on
    both desired future ecological outcomes and desired outputs of goods
    and services.  The Congress should be careful to ensure that the
    agency does not use the same performance goals and measures it used
    to pilot-test GPRA's performance planning and reporting requirements
    during fiscal years 1994 through 1996.\34 These performance goals and
    measures were linked both to the four goals in the Forest Service's
    October 1995 draft long-term strategic plan and to four very
    different goals in the agency's 1990 strategic plan:  (1) enhancing
    recreation, wildlife, and fisheries; (2) producing environmentally
    acceptable commodities; (3) improving scientific knowledge of natural
    resources; and (4) responding to global resource issues.\35 The four
    goals in the 1990 plan resulted in planned annual timber harvests
    from national forests of 11.1 billion board feet while the four goals
    in the 1995 draft plan resulted in planned annual timber harvests of
    4.5 billion board feet, or less than half the 1990 level.
    Performance goals and measures capable of assessing the progress made
    toward achieving both sets of long-term strategic goals and resulting
    planned annual timber harvest levels would, therefore, be
    meaningless.

    In commenting on our August 1994 report on ecosystem management, the
    Forest Service agreed that effectively implementing this management
    approach would require land managers to identify (1) the desired
    future ecological conditions; (2) the types, levels, and mixes of
    activities that can be sustained while still achieving these
    conditions; and (3) the distribution of these activities over time
    among the various land units within the ecosystem.  Thus,
    implementing the Forest Service's three long-term strategic goals for
    ecosystems would require forest managers to first identify desired
    future ecological conditions (outcomes); then identify the types,
    levels, and mixes of activities (outputs) that can be sustained while
    still achieving these conditions; and finally distribute these
    activities over time among the various land units within the
    ecosystem.  (See fig.  4.4.)

       Figure 4.4:  Relationships
       Between the Forest Service's
       Four Long-Term Strategic Goals
       and Practical Steps to
       Implement Ecosystem Management

       (See figure in printed
       edition.)

    --------------------
    \34 GPRA Performance Reports (GAO/GGD-96-66R, Feb.  14, 1996).

    \35 The Forest Service Program for Forest and Rangeland Resources:  A
    Long-Term Strategic Plan, Recommended 1990 RPA Program, Forest
    Service (May 1990).

          GPRA'S REQUIREMENTS MUST BE
          INTEGRATED INTO THE FOREST
          SERVICE'S DECISION-MAKING
          PROCESS
    -------------------------------------------------------- Chapter 4:3.4

    The February 25, 1997, letter also stated that the consultation
    process should include a discussion of the types of formats for
    strategic plans, performance plans, and performance reports that best
    meet the information needs of the Congress, federal line managers,
    and the general public.  To comply with this directive, the Forest
    Service would have to integrate the requirements of GPRA into its
    current decision-making process.

    The Forest Service is planning to develop two long-term strategic
    plans--one to comply with the requirements of GPRA and another to
    comply with the more extensive requirements of RPA.  Hearings held by
    the Senate Committee on Energy and Natural Resources during the 104th
    Congress concluded that the plans developed under RPA have been
    continually altered by other federal agencies and routinely ignored
    by the Forest Service as a guide to the development of forest plans
    and management activities.  Similarly, a 1990 OTA report states that
    plans developed under RPA are "of questionable usefulness to the
    agency, the Administration, and the Congress" because they ignore
    requirements in the act to discuss budget priorities and evaluate the
    plans' implementation in annual reports.\36 In light of the current
    tight budget climate and the annual competition for scarce resources
    within the agency, as well as the overlap in the requirements for
    strategic planning under RPA and GPRA, the Forest Service's current
    intention to develop two strategic plans appears to duplicate
    existing planning requirements rather than integrate GPRA's
    requirements into the agency's decision-making process.

    In addition, forest plans are intended to provide a key link between
    the Forest Service's long-term strategic goals and planned projects.
    (See app.  I.) However, many variables affect the outcomes of the
    agency's decisions.  As a result, the Forest Service often cannot
    achieve the objectives in its forest plans during the 10 to 15 years
    covered by the plans.  To account for the effects of variables such
    as changing natural conditions and funding, as well as new
    information and events, that can prevent the Forest Service from
    achieving the objectives in its forest plans, some agency officials
    have suggested that the agency (1) shorten the periods covered by the
    plans to 3 to 5 years, (2) link forest plans more closely to
    budgeting, and (3) include objectives for goods and services and
    desired conditions for resources at various funding levels in the
    forest plans.  But rather than adopt these changes, the Forest
    Service has proposed removing from its forest plans measurable
    objectives for goods and services, such as quantities of wood for
    lumber and forage for livestock and numbers of opportunities for
    recreation.  Without measurable objectives for goods and services in
    the forest plans, the Forest Service must find another link between
    its (1) long-term strategic goal of providing multiple benefits to
    satisfy people's needs for uses, values, products, and services
    within the capabilities of ecosystems and (2) annual performance
    goals and measures for gauging the progress made toward achieving the
    long-term goals and holding line managers accountable for their
    performance.

    The February 25, 1997, letter also stated that the federal agencies
    should be prepared to explain how the plans and reports required by
    GPRA will be used in the day-to-day management of the agency.  We
    have found that integrating human resource management activities into
    the Forest Service's organizational mission, rather than treating
    them as isolated support functions, could improve the implementation
    of GPRA.\37 This sort of integration may include tying individual
    performance management, career development programs, and pay and
    promotion standards to the Forest Service's strategic goals.

    --------------------
    \36 Forest Service Planning:  Setting Strategic Direction Under RPA
    (OTA-F-441, July 1990).

    \37 Transforming the Civil Service:  Building the Workforce of the
    Future, Results of A GAO-Sponsored Symposium (GAO/GGD-96-35, Dec.
    26, 1995).

       CONCLUSIONS
    ---------------------------------------------------------- Chapter 4:4

    As discussed in chapter 3, the failure of the Forest Service to give
    adequate attention to improving accountability for its performance
    and results has resulted in long-standing deficiencies within its
    decision-making process that have contributed to increased costs and
    time and/or the inability to achieve planned objectives.  GPRA, if
    implemented successfully, will strengthen accountability for
    performance and results within the agency and improve the efficiency
    and effectiveness of its decision-making.  However, as noted by the
    internal Forest Service task force on accountability, successful
    implementation of the act will depend on (1) strong leadership within
    the agency to change an organizational culture of indifference toward
    accountability and (2) sustained oversight by the Congress to provide
    the external attention to the issue needed to prompt corrective
    action.

    Successfully implementing GPRA includes consulting with the Congress.
    The desired outcome of the consultation between the Forest Service
    and the Congress would include an agreement on the agency's long-term
    strategic goals.  For such an agreement to occur, the Forest Service
    would need to clearly outline the logic and thinking behind its
    increasing emphasis on sustaining wildlife and fish under its broad
    multiple-use and sustained-yield mandate and indicate how it would
    resolve conflicts or make choices among competing uses on its lands
    under its proposed long-term strategic goals.

    The Congress could, in turn, accept or reject the agency's increasing
    shift in emphasis from producing timber to sustaining wildlife and
    fish and acknowledge the effects of this shift on the availability of
    other uses on the national forests.  Through consultation, the Forest
    Service and the Congress might also identify legislative changes that
    are needed to clarify or modify the Congress's intent and
    expectations or to address changes in conditions and/or citizens'
    needs that have occurred since the Organic Administration Act and
    Multiple-Use Sustained-Yield Act were enacted.

    If the four goals in the Forest Service's October 1995 draft
    long-term strategic plan remain unchanged, the Congress could expect
    to see (1) performance goals and measures based on both desired
    future ecological outcomes and desired outputs of goods and services
    and (2) individual performance management, career development
    programs, and pay and promotion standards tied to the strategic
    goals.  For its part, the agency could expect to see annual
    appropriations that are consistent with its mission priorities.

    The Congress and the Forest Service must also consider how best to
    integrate the requirements of GPRA into the agency's current
    decision-making process.  On the one hand, the Congress needs to
    consider the benefits and costs of the agency's developing two
    long-term strategic plans--one to comply with the requirements of
    GPRA and another to comply with the more extensive requirements of
    RPA.  On the other hand, the Forest Service needs to identify how it
    will link its long-term strategic goal of providing multiple benefits
    to satisfy people's needs for uses, values, products, and services
    within the capabilities of ecosystems with its annual performance
    goals and measures for gauging the progress made toward achieving the
    long-term goal and holding line managers accountable for their
    performance if it removes from its forest plans measurable objectives
    for goods and services.

       MATTER FOR CONGRESSIONAL
       CONSIDERATION
    ---------------------------------------------------------- Chapter 4:5

    In light of (1) the current tight budget climate, (2) the annual
    competition for scarce resources within the Forest Service, and (3)
    the questionable value of the agency's current long-term strategic
    plan, we recommend that the Congress consider amending the Forest and
    Rangeland Renewable Resources Planning Act to eliminate its
    requirement that the Forest Service develop a strategic plan covering
    a period of a decade or more.  The agency would still be required to
    develop a long-term strategic plan covering a period of at least 5
    years to comply with the requirements of the Government Performance
    and Results Act.

       RECOMMENDATION TO THE SECRETARY
       OF AGRICULTURE
    ---------------------------------------------------------- Chapter 4:6

    Because the Forest Service has proposed removing from its forest
    plans measurable objectives for goods and services, such as
    quantities of wood for lumber and forage for livestock and numbers of
    opportunities for recreation, we recommend that the Secretary of
    Agriculture direct the Chief of the Forest Service to identify how
    the agency will link its long-term strategic goal of providing
    multiple benefits to satisfy people's needs for uses, values,
    products, and services within the capabilities of ecosystems with its
    annual performance goals and measures for gauging the progress made
    toward achieving the long-term goal and holding line managers
    accountable for their performance.

       AGENCY COMMENTS AND OUR
       EVALUATION
    ---------------------------------------------------------- Chapter 4:7

    In commenting on our draft report, the Forest Service said that it
    intends to consult on its strategic goals with the Congress and the
    public, but neither it nor the Council on Environmental Quality
    commented on the matter for congressional consideration.

    In commenting on our draft report, the Forest Service did not
    directly address our recommendation to the Secretary of Agriculture
    but identified several actions that, if implemented, would improve
    the efficiency and effectiveness of its decision-making process.
    These actions include establishing strategic goals and related
    performance measures for managers as well as working in partnership
    with other agencies more closely and issuing revised regulations for
    implementing the National Forest Management Act.  However, the agency
    did not discuss either a schedule to implement the improvements or a
    plan to closely monitor progress and periodically report on
    performance, both of which GAO believes are needed to break the cycle
    of studying and restudying issues without any accountability or clear
    sequence for resolving them.

    INTERAGENCY ISSUES AFFECT THE
    FOREST SERVICE'S DECISION-MAKING
    ============================================================ Chapter 5

    Issues that transcend the Forest Service's administrative boundaries
    and jurisdiction also adversely affect the efficiency and
    effectiveness of the agency's decision-making.  In particular, the
    Forest Service and other federal land management agencies have had
    difficulty reconciling the administrative boundaries of national
    forests, parks, and other federal land management units with the
    boundaries of natural systems, such as watersheds and vegetative and
    animal communities, both in planning and in assessing the cumulative
    impact\1 of federal and nonfederal activities on the environment.

    Over the past few years, several major studies have examined the need
    to reconcile the differences in the geographic areas that federal
    agencies must consider when reaching decisions.  Among the options
    that have been suggested are changes to the Council on Environmental
    Quality's (CEQ) regulations and guidance implementing the provisions
    of the National Environmental Policy Act (NEPA).  According to CEQ
    officials, changes to NEPA regulations and guidance are not being
    considered at this time.  Instead, CEQ plans to rely primarily on
    interagency agreements.  However, interagency agreements (1) have not
    been lived up to by agencies in the past, (2) are generally not
    enforceable by outside parties, and (3) do not provide a basis for
    common approaches among all agencies.  Moreover, since federal
    agencies sometimes do not work efficiently and effectively together
    to address issues that transcend their boundaries and jurisdictions
    and often lack the environmental and socioeconomic data required to
    make informed decisions, strong leadership by CEQ would help to
    ensure that interagency agreements accomplish their intended
    objectives.

    --------------------
    \1 Regulations issued in 1978 by the Council on Environmental Quality
    to implement the provisions of the National Environmental Policy Act
    require federal agencies to assess the effects of a proposed action
    on such resources as water, wildlife, and soils in combination with
    those of other past, present, and reasonably foreseeable future
    actions occurring on both federal and nonfederal lands.

       DIFFERENCES BETWEEN
       ADMINISTRATIVE AND ECOLOGICAL
       BOUNDARIES ARE SOMETIMES
       DIFFICULT TO RECONCILE
    ---------------------------------------------------------- Chapter 5:1

    The Forest Service and other federal land management agencies have
    had difficulty reconciling differences in the geographic areas that
    must be considered in reaching decisions under different planning and
    environmental laws.  This difficulty has increased the costs, time,
    and complexity of the Forest Service's and other federal land
    management agencies' decision-making.

    The Forest Service and other federal land management agencies are
    authorized by laws such as the National Forest Management Act (NFMA)
    to plan primarily along administrative boundaries, such as those
    defining forests, parks, resource areas, and wildlife refuges.
    Conversely, environmental statutes and regulations require the
    agencies to analyze environmental issues and concerns along the
    boundaries of natural systems, such as watersheds, airsheds, soils,
    and vegetative and animal communities.  For example, regulations
    implementing NEPA require the agencies to assess the cumulative
    impact of federal and nonfederal activities on the environment.

    Because the boundaries of administrative units and natural systems
    are frequently different,\2 federal land management plans have often
    considered effects only on those portions of natural systems or
    portions of their components--such as the habitats of threatened and
    endangered species, the flyways of migratory birds, and
    wetlands--that exist within the boundaries of the administrative
    units covered by the plans.  For example, a widely recognized
    boundary of the Greater Yellowstone ecological unit in Montana,
    Wyoming, and Idaho encompasses all or part of seven national forests,
    two national parks, and three national wildlife refuges--most of
    which are covered by different plans--as well as other federal and
    nonfederal lands (see fig.  5.1)

       Figure 5.1:  Boundary Suggested
       for the Greater Yellowstone
       Ecological Unit

       (See figure in printed
       edition.)

       Source:  Greater Yellowstone
       Coalition.

       (See figure in printed
       edition.)

    The effects of the resulting inconsistencies on management were
    evident in some of the forests we visited.  The Tahoe National Forest
    in northern California, for example, is a checkerboard of federal and
    private lands, created when the federal government granted
    alternating sections of land to railroad companies.  Tahoe officials
    told us that planning and managing for diverse plant and animal
    communities, as required by NFMA, is difficult when the boundaries of
    the forest are not consistent with those of species' habitats.

    Not analyzing the effects of decisions on natural systems and their
    components at the appropriate ecological scale can result in
    duplicative environmental analyses for individual plans and projects,
    increasing the costs and time required for analysis and reducing the
    effectiveness of federal land management agencies' decision-making.
    In particular, federal land management plans and projects often
    consider effects only on portions of natural systems or portions of
    the habitats of wide-ranging species, such as migratory birds, bears,
    and anadromous fish (including salmon).\3

    According to an interagency task force chaired by CEQ,\4 it is not
    uncommon for multiple environmental analyses to be filed for
    individual agencies' actions, even though the activities occur in the
    same region or even at the same site.

    Similarly, two resolutions sent by the Western Governors' Association
    in 1996 to the President, federal agencies, and congressional
    committee chairs\5 expressed concern over NEPA's implementation.  One
    cited "duplicative environmental analyses of projects by multiple
    federal agencies .  .  .  each with its own set of NEPA regulations
    and processes which further adds confusion and complexity." In a
    second resolution, the governors noted that the "current
    implementation of NEPA analysis at multiple levels has created a
    strain on resources of federal, state, and local governments and the
    private sector.  Associated delays are counter to the interests of
    all levels of government."

    --------------------
    \2 Ecosystem Management:  Additional Actions Needed to Adequately
    Test a Promising Approach (GAO/RCED-94-111, Aug.  16, 1994).

    \3 See, for example, Final Report of Recommendations:  Project-Level
    Analysis Re-Engineering Team, Forest Service (Nov.  17, 1995).

    \4 The Ecosystem Approach:  Healthy Ecosystems and Sustainable
    Economies, Vol.  II, Implementation Issues, Report of the Interagency
    Ecosystem Management Task Force (Nov.  1995).

    \5 Resolution 96-005, "Implementation of the National Environmental
    Policy Act," and Resolution 96-011, "Future Management of the
    National Forests and Public Lands," Western Governors' Association
    (Omaha, Neb.:  June 1996).

             CUMULATIVE IMPACT IS
             DIFFICULT TO ASSESS
    ------------------------------------------------------ Chapter 5:1.0.1

    Government, academic, business, and nongovernmental organizations
    that participated in a study by CEQ of NEPA's effectiveness,
    published in 1997, underscored that assessing the cumulative impact
    of a decision "magnifies the difficulty" of performing NEPA
    analyses.\6 In addition, prior GAO work has shown that the Forest
    Service and other federal agencies have, in many instances, not
    complied with the requirement for assessing a decision's cumulative
    impact.  For instance, in June 1990,\7 we reported that 71 of 82
    land-use plans and related environmental impact statements covering
    Bureau of Land Management and Forest Service lands having high oil
    and gas potential did not cite the cumulative impact of a reasonably
    foreseeable development scenario.  A number of the agencies'
    decisions had been challenged and leasing suspended--primarily on
    Forest Service lands--on the basis of inadequate information about
    environmental effects.  These actions had resulted in lost or delayed
    federal revenues.

    For example, the Forest Service's Region 1, which covers 24 million
    acres and includes 15 forests in northern Idaho, Montana, North
    Dakota, and northwestern South Dakota, suspended leasing in 1985
    following a district court's decision that the Forest Service had not
    adequately assessed the environmental effects of its leasing
    decisions.\8 In 1990, we estimated that about $9.6 million in rental
    revenue was lost annually on the 5.4 million acres that the agency
    believed would have been leased in the region and on leases that had
    been suspended because existing environmental studies did not comply
    with NEPA's provisions.

    We found evidence during our current work that the Forest Service is
    still experiencing difficulty in complying with the requirement for
    assessing cumulative impact.  For example, in a 1996 response to
    public comments on a proposed salvage timber sale in the Idaho
    Panhandle national forests, a Forest Service district ranger stated
    that the agency's "analysis of direct, indirect, and cumulative
    impact includes effects of management activities on National Forest
    System lands only." By contrast, NEPA regulations require the agency
    to consider the effects on natural systems of past, present, and
    reasonably foreseeable future actions occurring on both federal and
    nonfederal lands.

    Forest Service officials in headquarters and several field locations
    that we visited during this review told us that compliance with the
    requirement for assessing cumulative impact is often difficult
    because some effects cannot be adequately determined before a forest
    plan is approved or a project-level decision is reached owing to
    scientific uncertainty and/or the prohibitive costs of obtaining the
    necessary data.  For example, officials performing a broad-scoped
    environmental analysis for the Interior Columbia River Basin\9 told
    us that the basin contains 74 separate federal land units, each with
    its own management plan and information database.  In addition, about
    40 percent of the acreage within the basin is privately owned and
    managed, further complicating assessments of cumulative impact.  As a
    result, some Forest Service officials believe that, for some
    projects, enhanced monitoring and evaluation may be more efficient
    and effective in assessing cumulative impact than additional NEPA
    analyses.  As stated in chapter 3, adopting this approach would
    require the agency to identify how a decision would be modified when
    new information is uncovered or when preexisting monitoring
    thresholds are crossed; however, the Forest Service has historically
    not complied with the monitoring requirements of NFMA.

    --------------------
    \6 The National Environmental Policy Act:  A Study of Its
    Effectiveness After Twenty-Five Years, CEQ, Executive Office of the
    President (Jan.  1997).

    \7 Federal Land Management:  Better Oil and Gas Information Needed to
    Support Land Use Decisions (GAO/RCED-90-71, June 27, 1990).

    \8 Conner v.  Burford, 605 F.  Supp.  107 (D.  Mont.  1985).

    \9 The Interior Columbia River Basin covers 145 million acres--or 8
    percent of the nation's surface area.  It is located mainly in
    Oregon, Washington, Idaho, and Montana but also covers small portions
    of northern California, Nevada, Utah, and Wyoming.  The basin
    includes 35 national forests, comprising about one-fourth of the
    National Forest System's lands.

       CHANGES TO REGULATIONS AND
       GUIDANCE HAVE BEEN SUGGESTED
    ---------------------------------------------------------- Chapter 5:2

    Over the past few years, several major studies have examined the need
    to reconcile the differences in the geographic areas that federal
    agencies must consider when reaching decisions and assessing the
    cumulative impact of federal and nonfederal activities on the
    environment.\10 Among the options that have been suggested are
    changes to CEQ's regulations and guidance for implementing the
    provisions of NEPA.  The Forest Service and other federal agencies
    are currently allowed, but not required, to tier, or link, plans and
    projects to broader-scoped studies.  One option that has been
    suggested is that CEQ amend its regulations to require that a NEPA
    analysis accompanying a plan or project (1) be tiered to
    broader-scoped studies and (2) concentrate on issues specific to the
    area covered by the plan or project.  However, according to CEQ
    officials, changes to NEPA regulations and guidance are not being
    considered at this time.

    To reconcile natural and administrative boundaries and to better
    assess the cumulative impact of their decisions, as CEQ's regulations
    require, the Forest Service and other federal agencies are currently
    examining the efficiency and effectiveness of using broader-scoped
    environmental analyses.  These analyses have been performed in areas
    such as the Interior Columbia River Basin and the Sierra Nevada
    mountains in California.

    According to the Chief of the Forest Service, such analyses can
    result in more efficient planning and a better understanding of
    conditions, trends, and forests' health, allowing ongoing projects to
    continue uninterrupted.  Similarly, the 1995 report by the
    interagency task force chaired by CEQ and a 1995 report by a Forest
    Service reengineering team\11 state that broader-scoped analyses can
    be cost-effective in the long run because they (1) eliminate the
    redundancy involved in performing many smaller analyses for
    individual projects and (2) tailor the analyses, including those
    addressing cumulative impact, to the appropriate ecological scale.

    The task force and the reengineering team both believed that tiering
    site-specific analyses to broader-scoped studies would allow agencies
    to conduct project-level NEPA analyses more efficiently.  When a
    broader-scoped study has been performed, tiering allows the
    project-level environmental analysis to concentrate on issues
    specific to the project and to explain how the project relates to the
    issues discussed in the broader-scoped study.

    The task force noted other benefits that accrue from broad-scoped
    interagency NEPA analyses.  These benefits include (1) ensuring the
    consideration of cumulative impact and management strategies at a
    scale that may be overlooked in site-specific NEPA documents; (2)
    allowing federal agencies to share resources and expertise and
    minimizing agencies' working at cross-purposes; (3) creating a
    baseline for sharing information; (4) reorienting analyses toward
    proactive, preventive efforts in anticipation of issues, such as the
    listing of a species under the Endangered Species Act (ESA), before
    concrete proposals are made; and (5) establishing coordinated
    monitoring approaches and avoiding duplicative or ineffective
    monitoring at site-specific levels by different agencies.

    The task force also cited potential drawbacks of broader-scoped
    analyses.  These drawbacks include (1) possible inefficiencies and
    ineffectiveness in the use of resources created by adding a level of
    NEPA documentation and (2) the potential limited usefulness of such
    broader-scoped studies--and their vulnerability to legal
    challenges--caused by uncertainty over such issues as the appropriate
    ecological scale for analysis.

    The task force suggested two options for broader-scoped studies:  (1)
    federal agencies could voluntarily conduct broader-scoped analyses,
    which could then be used only as "guides" during the agencies'
    decision-making processes and would not be subject to CEQ's
    regulations or (2) CEQ could revise its regulations to require
    tiering.  The task force noted that "CEQ's views are entitled to
    substantial deference in the courts" and that

         "to improve implementation and reduce litigation risk, CEQ could
         issue regulations or guidance, building upon its recent report
         on incorporating biodiversity into NEPA analysis.  .  .  .\12
         Among other things, the regulations or guidance could identify
         important ecological assessment techniques and core ecological
         issues, including multiple ecological scales and long-term
         ecological timeframes."

    Similarly, a 1996 report by a former CEQ official concluded that "CEQ
    has never been more needed .  .  .  for dealing with increasingly
    difficult environmental problems" and "seeing to it that government
    efforts produce results in an economically efficient manner and not
    just greater bureaucracy, waste and frustration." The report further
    noted that "CEQ's regulations will need periodic refinement and
    nudging" and echoed the task force in stating that "courts give great
    deference to CEQ's regulations."\13

    In addition, a 1996 report by 50 government, industry, and
    environmental officials suggested that CEQ's and federal land
    management agencies' regulations be reviewed and appropriately
    revised to better address larger, landscape-scale issues.\14 Federal
    agency, industry, and environmental experts with whom we spoke also
    identified the need for CEQ to require, rather than allow,
    site-specific analyses to be tiered to broader-scoped studies.

    At an October 1995 hearing before the Senate Energy and Natural
    Resources Committee, the Chair of CEQ agreed to work with the
    Committee to ensure that NEPA is implemented as efficiently and
    effectively as possible.  After the hearing, the Chairmen of two of
    the Committee's Subcommittees sent a letter to the Chair of CEQ
    expressing their and other Committee members' frustration with CEQ's
    apparent reluctance to streamline the NEPA process and suggesting
    that CEQ and the Forest Service work together to revise their
    regulations so that they prospectively identify (1) the scope of the
    environmental analysis and (2) the NEPA documents required at each
    level of decision-making.  In the letter, the Subcommittee Chairmen
    strongly recommended that the revision attempt to outline a system of
    tiered NEPA documentation showing how the levels of analysis are
    related and at what level and under what circumstances specific types
    of decisions are made.

    CEQ's study of NEPA's effectiveness, published over a year after the
    two Subcommittee Chairmen wrote their letter, does not directly
    discuss amending CEQ's regulations to require tiering and to identify
    the NEPA documents required for decision-making.  Instead, the study
    restates the issues that the interagency task force identified in
    1995 as important to the efficient and effective implementation of
    the act.  And, rather than make recommendations to improve the
    efficiency and effectiveness of the NEPA process, the study promises
    that CEQ will embark on a third major effort to reinvent the NEPA
    process over the next several years.  According to CEQ officials,
    this effort to reinvent NEPA will not consider changes to CEQ's
    implementing regulations.

    --------------------
    \10 See, for example, footnotes 2, 3, and 4.

    \11 See footnote 3.

    \12 Incorporating Biodiversity Considerations Into Environmental
    Impact Analyses under the National Environmental Policy Act, CEQ
    (Jan.  1993).

    \13 Boyd Gibbons, "CEQ Revisited:  The Role of the Council on
    Environmental Quality," Henry M.  Jackson Foundation (1996).

    \14 The Keystone National Policy Dialogue on Ecosystem Management:
    Final Report, The Keystone Center (Keystone, Colo:  1996).

       EFFORTS WILL CONTINUE TO RELY
       PRIMARILY ON INTERAGENCY
       AGREEMENTS
    ---------------------------------------------------------- Chapter 5:3

    Rather than change its NEPA regulations to require that site-specific
    analyses be tiered to broader-scoped studies, CEQ plans to rely
    primarily on interagency agreements as a means of resolving issues
    that transcend the administrative boundaries and jurisdictions of
    federal agencies.  Several major studies of federal land management
    decision-making performed during the 1990s have identified the
    benefits of better interagency coordination.  However, federal land
    management and regulatory agencies sometimes do not work efficiently
    and effectively together to address interagency issues.  As a result,
    the interagency task force chaired by CEQ recommended that CEQ expand
    its guidance and revise its NEPA regulations to promote interagency
    coordination.  However, according to CEQ officials, they have no
    plans to do so.

          BETTER INTERAGENCY
          COORDINATION IS CRITICAL TO
          IMPROVED DECISION-MAKING
    -------------------------------------------------------- Chapter 5:3.1

    Our 1994 report on the four major federal land management agencies'
    implementation of ecosystem management\15 states that broader-scoped
    environmental analyses will require unparalleled coordination among
    federal land management and regulatory agencies.  Similarly, the 1995
    report by the interagency task force chaired by CEQ and CEQ's 1997
    study of NEPA's effectiveness identified early interagency
    coordination as critical to efficient and effective decision-making.

    Our current work also shows that involving federal regulatory
    agencies at the beginning of the decision-making process and
    maintaining their involvement throughout the process may expedite
    decision-making.  For example, the Forest Service involved the Fish
    and Wildlife Service in developing alternatives for a major
    restoration project on the Wenatchee National Forest in Washington
    State.  These alternatives included timber harvesting.  Because the
    Fish and Wildlife Service was involved at the beginning of the
    decision-making process when problems were identified, data were
    gathered, and relationships were established and because it remained
    involved throughout the process, it was able to quickly concur with
    the Forest Service's preferred alternative.  The responsible Forest
    Service district ranger estimated that the Fish and Wildlife
    Service's early and continuous involvement was a major reason why
    only about half as much time was required to reach a decision for
    this project as for similar projects.  Similarly, the Fish and
    Wildlife Service has found that its participation in an interagency
    information-sharing group in the Southern Appalachian highlands (an
    area straddling the borders of Alabama, Georgia, North Carolina,
    South Carolina, Tennessee, and Virginia) has allowed it to inform the
    Forest Service and other federal land management agencies about the
    potential effects of contemplated projects before formal consultation
    becomes necessary.

    --------------------
    \15 See footnote 2.

          FEDERAL AGENCIES SOMETIMES
          DO NOT WORK WELL TOGETHER
    -------------------------------------------------------- Chapter 5:3.2

    Our 1994 report on ecosystem management, the 1995 report by the
    interagency task force chaired by CEQ, CEQ's 1997 study of NEPA's
    effectiveness, and other studies and reports have found that the
    Forest Service and other federal land management agencies do not
    always involve other federal agencies at the beginning of their
    decision-making processes and maintain the other agencies'
    involvement throughout their processes.

    For example, in its January 1997 study of NEPA's effectiveness, CEQ
    states that many federal agencies have failed to involve all
    interested federal agencies early and continuously in their
    decision-making processes.  Moreover, an interagency team that
    reviewed the "salvage rider" timber program observed in 1996 that,
    while coordination was working well in some places, in others
    "neither the letter nor the spirit of the collaborative process
    envisioned by the [memorandum of agreement was] observed, leaving
    significant conflicts unaddressed."\16

    Our work also showed that some delays in implementing forest plans
    and reaching project-level decisions resulted from inadequate
    interagency coordination at the beginning of and/or throughout the
    decision-making process.  Instead, some forests and districts limited
    the involvement by federal regulatory agencies primarily to reviewing
    and commenting on proposals that the forests or districts had
    developed.  For example, the Forest Service did not involve federal
    regulatory agencies at the beginning of the decision-making process
    for the Thunderbolt salvage timber sale on the Boise and Payette
    national forests in central Idaho, choosing instead to have the
    agencies review and comment on the preferred alternative developed by
    the forests.  The Fish and Wildlife Service, the National Marine
    Fisheries Service, and the Environmental Protection Agency (EPA)
    could not agree with the Forest Service on the risk posed by the sale
    to salmon-spawning habitat or the actions needed to mitigate the
    risk.  The agencies' inability to agree delayed the project's
    implementation.  Because salvage timber rapidly declines in value,\17
    the delay lowered the sale price, reducing the revenues to the
    federal government.

    Adequate coordination among the four major federal land management
    agencies has also not always occurred.  For instance, according to a
    November 1996 report by the Forest Service and the Bureau of Land
    Management summarizing scientific findings on the ecological status
    of the Interior Columbia River Basin,\18 continuing the management
    approaches established under existing land management plans would
    produce declining trends in resource conditions on 95 percent of the
    lands administered by the two agencies.  The report attributes the
    declining trends to the agencies' having developed the existing plans
    with little or no attention to coordinating their management.

    --------------------
    \16 Interagency Salvage Program Review, U.S.  Department of Commerce,
    National Oceanic and Atmospheric Administration, National Marine
    Fisheries Service (Silver Spring, Md.:  Oct.  8, 1996).

    \17 Public Timber:  Federal and State Programs Differ Significantly
    in Pacific Northwest (GAO/RCED-96-108, May 23, 1996).

    \18 Status of the Interior Columbia Basin:  Summary of Scientific
    Findings, General Technical Report PNW-GTR-385 (Nov.  1996).

          CEQ INTENDS TO RELY
          PRIMARILY ON INTERAGENCY
          AGREEMENTS
    -------------------------------------------------------- Chapter 5:3.3

    The November 1995 report by the interagency task force chaired by CEQ
    stated that the NEPA process provides a significant opportunity for
    interagency coordination and consultation on individual agencies'
    proposals.  However, despite the opportunities it creates for
    interagency collaboration, the NEPA process has not generally been
    used as a basis for coordinating federal activities across natural
    systems.  The task force concluded that the process could be used
    more effectively to promote collaboration and consensus-building
    among federal agencies and could serve as an important procedural
    mechanism for interagency coordination through, among other things,
    expanded CEQ guidance and revised NEPA regulations.  However, the
    task force directed its recommendations for improving interagency
    coordination to individual federal agencies rather than to CEQ, and,
    according to CEQ, it does not plan to expand its guidance or revise
    its NEPA regulations to promote interagency coordination.

    Instead, CEQ plans to rely on interagency agreements to improve
    coordination.  However, interagency agreements (1) have not been
    lived up to by agencies in the past, (2) are generally not
    enforceable by outside parties, and (3) do not provide a basis for
    common approaches among all agencies.  In its 1997 study of NEPA's
    effectiveness, CEQ states that the Forest Service and other federal
    land management and regulatory agencies have signed various
    memorandums of agreement to improve interagency coordination on
    forests' health and timber sales.  According to CEQ, these agreements
    have resulted in a 50-percent reduction in the time needed for
    environmental review, including a 75-percent reduction in the time
    required for ESA consultations.  Similarly, the interagency team that
    reviewed the salvage rider timber program observed that continuing
    and expanding early, collaborative involvement among the agencies
    reduced the time required to plan and implement salvage timber sales.
    However, as noted by the interagency salvage rider team, strong
    leadership will be needed to ensure that interagency cooperation and
    collaboration occur.

    Consistent with its plan not to consider changes to NEPA's
    regulations and guidance, CEQ conducted a 3-year study and issued a
    draft handbook in September 1996\19 to identify the current state of
    the science and provide practical direction on assessing cumulative
    impact in NEPA analyses.  The handbook (1) includes a disclaimer
    stating that it "is not formal guidance nor is it exhaustive or
    definitive, but rather it should assist practitioners in developing
    their own study-specific approaches" and (2) states in its preface
    that its recommendations "are not intended to be legally binding."

    The draft handbook lays out eight principles for agencies to use in
    analyzing cumulative impact, including using the boundaries of
    natural systems.  However, federal agencies have not agreed on how
    best to delineate the boundaries of the natural systems to be
    studied.  For example, the Forest Service has developed a hierarchy
    for delineating ecosystems, called the National Hierarchal Framework
    of Ecological Units.  (See fig.  5.2.) However, no other federal
    agency has officially adopted this framework for use in its
    decision-making, and some agencies have developed different
    hierarchies.  (See fig.  5.3.)

       Figure 5.2:  Forest Service's
       National Hierarchal Framework
       of Ecological Units

       (See figure in printed
       edition.)

       Source:  Forest Service.

       (See figure in printed
       edition.)

       Figure 5.3:  Fish and Wildlife
       Service's Ecological Unit Map

       (See figure in printed
       edition.)

       Source:  Fish and Wildlife
       Service.

       (See figure in printed
       edition.)

    The Forest Service and several other federal agencies have agreed to
    develop a common framework for delineating natural systems.  However,
    no such framework has been developed, and, although the agencies say
    that they intend to use such a framework, the agreement does not
    require them to do so for planning or for any other purpose.  In
    addition, federal agency, industry, and environmental experts with
    whom we spoke identified the benefits of CEQ's providing
    leadership--through regulations and formal guidance--that would
    ensure that federal agencies use a coordinated approach to
    delineating natural systems.  However, CEQ is not a signatory to the
    interagency agreement, nor does it have a defined role under the
    agreement.

    --------------------
    \19 Considering Cumulative Effects Under the National Environmental
    Policy Act, Final Draft, Interagency Review Version, CEQ (Sept.  24,
    1996).

       COMPLETE AND COMPARABLE DATA
       COULD IMPROVE THE AGENCIES'
       ABILITY TO CONDUCT STUDIES AND
       COORDINATE ACTIVITIES
    ---------------------------------------------------------- Chapter 5:4

    Effective interagency coordination is dependent on, among other
    things, comparable environmental and socioeconomic data that are
    useful and easily accessible to decisionmakers.  Useful and
    comparable environmental and socioeconomic data would also allow CEQ
    to better meet its responsibility under NEPA to provide the President
    and the Congress with annual assessments of national environmental
    conditions and trends, as well as evaluations of related federal
    programs and activities.  However, (1) the environmental and
    socioeconomic data gathered by federal agencies are often not
    comparable, and large gaps in the information exist; (2) federal
    agencies may not know who has what information, how existing data can
    be used, and how information can be made available within agencies,
    across agencies, and to the public; and (3) information is often not
    available because there is no mechanism for identifying, locating, or
    assessing it or for determining its nature and quality.

    A September 1995 report by the Environmental Law Institute\20
    recommends, as one option, that CEQ exercise its existing authority
    under NEPA to promulgate regulations creating an interagency
    database.\21 To accomplish this, CEQ could require federal agencies
    to maintain and make available consistent, adequate data for the
    agencies' use in decision-making and for CEQ's use in developing
    statutorily required annual assessments and evaluations.  According
    to CEQ, it does not plan to revise its regulations to require such
    data.  Rather, it intends to rely on several efforts already under
    way to develop the data.

    --------------------
    \20 The Environmental Law Institute is an independent research and
    education center funded by foundations, government, corporations, law
    firms, individuals, and other sources to convene diverse parties to
    work cooperatively to address environmental problems.

    \21 Rediscovering the National Environmental Policy Act:  Back to the
    Future, Environmental Law Institute (Sept.  1995).

          AVAILABLE DATA ARE NOT
          COMPARABLE
    -------------------------------------------------------- Chapter 5:4.1

    According to the 1995 report by the interagency task force chaired by
    CEQ, analyzing environmental issues and concerns at the appropriate
    ecological scale would require federal agencies to agree on the type
    of environmental information to be contributed and the format needed
    to make it readily accessible.  The task force also concluded that
    environmental reviews would benefit from a wider use of socioeconomic
    analyses.  Finally, the task force identified a critical need for an
    interagency database of ecological and socioeconomic information to
    facilitate agencies' compliance with informational requirements, such
    as the requirement for assessing cumulative impact under NEPA, and to
    ease compliance with requirements for interagency coordination.

    However, as noted in our 1994 report on ecosystem management,
    available data, collected independently by various agencies for
    different purposes, are often noncomparable and insufficient for
    decision-making.  Similarly, the interagency task force's report
    states that (1) frequently, the quality of the available data is
    inadequate or unknown; (2) a lack of consistency and comparability in
    collecting, analyzing, and storing data makes comparison difficult
    and continues to impede the creation of common databases and the
    sharing of existing data; and (3) the acquisition of software and
    hardware is rarely, if ever, coordinated, even among units within a
    single agency.  For example, officials performing the broad-scoped
    environmental analysis for the Interior Columbia River Basin told us
    that each of the 74 separate federal land units within the basin
    maintains its own information database and that the databases are
    often not consistent or comparable.  In addition, assessment of the
    socioeconomic effects of federal land management decisions was
    difficult because economic forecast data for counties and communities
    within the basin were limited.  Our 1994 report on ecosystem
    management stated that many of the required socioeconomic data--on
    employment, production, and commerce--are gathered and/or maintained
    by federal, state, and local agencies; firms; private researchers;
    and industry organizations for many different purposes and are often
    noncomparable, insufficient, or uncertain.

    CEQ's 1997 study of NEPA's effectiveness states that although
    obtaining adequate environmental data is the key to a thorough
    scientific review of a decision's cumulative impact, the current lack
    of high-quality environmental baseline data severely hampers the
    accomplishment of this requisite.  Just as we observed of the Forest
    Service (see ch.  3), CEQ's study found that the four major federal
    land management agencies do not know the extent or location of
    archeological sites, wetlands, or other important environmental
    features.  Moreover, the Forest Service does not maintain or have
    access to a database containing the results of environmental analyses
    conducted under NEPA by other federal agencies or even by national
    forests or ranger districts.  As a result, it does not know who has
    what information or how the data could be used to assess cumulative
    impact or other environmental effects.

          EFFORTS ARE UNDER WAY TO
          IMPROVE DATA
    -------------------------------------------------------- Chapter 5:4.2

    Two statutes--the Clinger-Cohen Act of 1996 and the Paperwork
    Reduction Act of 1995--provide a statutory framework and processes
    for CEQ to address interagency data needs.  Both acts require CEQ and
    other federal agencies to examine and devise ways by which they can
    better carry out their missions through the use of improved
    information systems, including setting goals, establishing
    performance measurements, and reporting on progress.  Additionally,
    the Paperwork Reduction Act provides that the Office of Management
    and Budget, also within the Executive Office of the President, may
    (1) designate a central collection agency, such as CEQ or another
    federal agency that CEQ might recommend, to obtain information for
    two or more agencies with similar data needs; (2) direct the sharing
    of information; and (3) require that agencies participate in
    establishing and maintaining a service through which they can locate,
    retrieve, and share commonly used information with one another and
    the public.

    Several efforts are under way to develop comparable environmental and
    socioeconomic data that are useful and easily accessible to
    decisionmakers.  For example, the Forest Service and other federal
    agencies have developed a common geographic information system (GIS)
    for the old-growth forests of the Pacific Northwest.  The system is
    intended to (1) provide consistent data; (2) reduce duplication of
    effort; and (3) support the detailed environmental analyses needed
    for project-level decisions, forest plans, and analyses of cumulative
    impact for an entire region.  The Forest Service and other federal
    agencies have also developed a data system for the Interior Columbia
    River Basin, which is intended to establish the relative ecological
    integrity and health of different areas as a basis for devising
    management strategies.  In addition, the Forest Service and/or other
    federal agencies are developing data systems for other regions of the
    nation, including the Southern Appalachian highlands and the Great
    Lakes.  However, differences among these systems may impede the
    analysis and sharing of data.

    A Federal Geographic Data Committee, chaired by the Secretary of the
    Interior, is developing a national spatial data infrastructure\22 to
    improve the knowledge of and access to information.  Specifically,
    the infrastructure is conceived to be an umbrella of policies,
    standards, and procedures under which organizations and technologies
    interact to foster the more efficient use, management, and production
    of geospatial data.  Critical to the infrastructure's success is the
    participation of data generators, such as the federal government.
    When completed, this infrastructure should greatly improve
    information in a wide range of areas, including the analysis of
    environmental information and the monitoring of species listed under
    ESA and of sensitive land areas, such as wetlands.\23

    However, no agreement exists among the Forest Service and other
    federal agencies on a consistent approach for using this information
    to assess common problems and issues in the same geographic areas.
    Some Forest Service officials have asked CEQ to take the lead in
    developing a common approach for assessing the data; however, CEQ has
    not yet responded to their request.

    --------------------
    \22 Spatial or geographic data refer to information that can be
    placed on a map.

    \23 Management Reform:  Implementation of the National Performance
    Review's Recommendations (GAO/OCG-95-1, Dec.  5, 1994) and Management
    Reform:  Completion Status of Agency Actions Under the National
    Performance Review (GAO/GGD-96-94, June 12, 1996).

       CONCLUSIONS
    ---------------------------------------------------------- Chapter 5:5

    Improving the efficiency and effectiveness of the Forest Service's
    decision-making, as well as reducing the costs, time, and complexity
    of federal land management in general, will require federal agencies
    to adequately address issues that transcend their administrative
    boundaries and jurisdictions.  In particular, they will need to
    reconcile the administrative boundaries along which they are
    authorized to plan with the ecological boundaries of the natural
    systems and components that they are required to protect and
    conserve.

    Studies have suggested that CEQ's regulations for implementing NEPA
    be changed to require, rather than merely allow, federal agencies to
    tier plans and projects to broader-scoped studies and that CEQ's
    regulations and guidance be changed to improve interagency
    coordination and collaboration and to provide federal decisionmakers
    with useful and comparable environmental and socioeconomic data.
    Among the benefits of changing the regulations and guidance would be
    a reduced risk that decisions would be challenged over issues such as
    the appropriate ecological scale for analysis.

    Instead of revising its regulations or issuing guidance, CEQ has
    chosen to rely primarily on interagency agreements to address
    interagency issues.  However, interagency agreements (1) have not
    been lived up to by agencies in the past, (2) are generally not
    enforceable by outside parties, and (3) do not provide a basis for
    common approaches among all agencies.  Moreover, federal land
    management and regulatory agencies sometimes do not work efficiently
    and effectively together to address issues that transcend their
    boundaries and jurisdictions.  While strong leadership by CEQ would
    help to ensure that interagency agreements accomplish their intended
    objectives, CEQ may also need to consider changes to regulations and
    guidance in its planned effort to reinvent federal agencies'
    implementation of NEPA.

       RECOMMENDATIONS TO THE CHAIR OF
       THE COUNCIL ON ENVIRONMENTAL
       QUALITY
    ---------------------------------------------------------- Chapter 5:6

    To ensure that CEQ's planned multiyear effort to reinvent NEPA's
    implementation improves the efficiency and effectiveness of the NEPA
    process, we recommend that the Chair of CEQ

      -- change CEQ's regulations implementing NEPA to require, rather
         than merely allow, federal agencies to tier plans and projects
         to broader-scoped studies and

      -- change CEQ's regulations and guidance implementing NEPA to
         improve interagency coordination; identify a baseline of
         comparable environmental and socioeconomic data that are needed
         for agencies to implement the act; and assume or assign
         responsibility for collecting, managing, and making the data
         available to other users.

    We do not recommend precise changes to CEQ's regulations or guidance
    because we believe such changes are better left to CEQ to determine
    on the basis of its own internal study and evaluation of the outside
    views solicited during its NEPA reinvention effort.

       AGENCY COMMENTS AND OUR
       EVALUATION
    ---------------------------------------------------------- Chapter 5:7

    In its comments, CEQ agreed with the underlying goals articulated in
    our report for implementing NEPA but discussed different mechanisms
    that it is using to achieve these goals.  These mechanisms include
    streamlining procedures at individual agencies and examining issues
    on a sector-by-sector basis (e.g., timber, grazing, and oil and gas).
    We agree with CEQ that (1) differences among the cultures,
    organizations, and institutional goals of various federal agencies,
    as well as the substantive nature of their underlying missions,
    require CEQ's regulations implementing the act to be generic in
    nature and (2) regulatory changes often need to be tailored
    specifically to the agencies' individual processes.  However, the
    thrust of our recommendation to the Chair of CEQ is intended to
    ensure that the Council's planned multiyear reinvention effort does
    not prematurely or arbitrarily close off options for improving the
    efficiency and effectiveness of the act's implementation across
    federal agencies' administrative boundaries and jurisdictions.

    DIFFERENCES IN LAWS' REQUIREMENTS
    AFFECT THE FOREST SERVICE'S
    DECISION-MAKING
    ============================================================ Chapter 6

    Differences in the requirements of planning and environmental laws,
    enacted primarily during the 1960s and 1970s, produce inefficiency
    and ineffectiveness in the Forest Service's and other federal
    agencies' decision-making.  Requirements to consider new information
    and events and differing judicial interpretations of the same
    statutory requirements have increased the costs and time of
    decision-making and have made it difficult for the Forest Service and
    other federal agencies to predict when any given decision can be
    considered final and can be implemented, reducing the ability of the
    agencies to achieve the objectives in their plans.  Additional
    differences among statutorily required approaches for protecting
    various resources--such as endangered and threatened species, water,
    air, diverse plant and animal communities, and wilderness--have also
    sometimes been difficult to reconcile.

    Adequately addressing these and other concerns would require a
    systematic and comprehensive analysis of the laws to avoid making
    changes that would entail unintended consequences for the future.
    However, statutory changes to improve the efficiency and
    effectiveness of the Forest Service's decision-making process cannot
    be identified until agreement is first reached on which uses the
    agency is to emphasize under its broad multiple-use and
    sustained-yield mandate and how it is to resolve conflicts or make
    choices among competing uses on its lands.

       REQUIREMENTS TO CONSIDER NEW
       INFORMATION AND EVENTS ENTAIL
       ONGOING REVIEWS OF PLANS AND
       PROJECTS
    ---------------------------------------------------------- Chapter 6:1

    Responding to new information and events can lead the Forest Service
    to recycle forest plan and project decisions.  Under the National
    Environmental Policy Act (NEPA), federal agencies have an ongoing
    duty to evaluate new information relevant to the environmental
    effects of proposed actions.  Under the Endangered Species Act (ESA),
    any new listing of a species as endangered or threatened, designation
    of habitat deemed critical to a listed species' protection, or
    discovery of new information requires that plans and projects be
    reviewed to determine their potential to affect listed species or
    their habitats.

    For instance, the listing of a species as endangered or threatened
    under ESA after a forest plan has been approved can require the
    Forest Service to reinitiate formal consultations with the Fish and
    Wildlife Service and/or the National Marine Fisheries Service to
    amend or revise the plan.  The listing may also stop the agency from
    implementing projects under the plan that could affect the species
    until the new round of consultations has been completed.

    For example, recent federal court decisions\1 required the Forest
    Service to reinitiate formal consultations on several approved forest
    plans because a species of salmon in the Pacific Northwest and a
    species of owl in the Southwest were listed as threatened under ESA.
    The courts' rulings prohibited the agency from implementing projects
    under the plans that might have affected the species until the new
    rounds of consultations with the Fish and Wildlife Service and/or the
    National Marine Fisheries Service had been completed.

    While new information and events can affect the outcomes of the
    Forest Service's decisions and prevent the agency from achieving the
    objectives in its forest plans or from implementing planned projects,
    the agency sometimes has not adequately anticipated the listing of
    candidate species or the designation of critical habitat.  (See ch.
    4.) Had the agency been better prepared, there would have been less
    likelihood that it would have been surprised by the listing of
    species under ESA after the plans were approved.  For example, the
    Chief of the Forest Service informed us that the agency could be
    producing more timber now in the Pacific Northwest and Southwest
    regions if it had followed the advice of its specialists and taken
    action to protect the habitats of candidate species, such as the
    northern spotted owl and Mexican spotted owl, before they were listed
    under ESA and the agency was required by the courts to reduce timber
    harvests.

    --------------------
    \1 Pacific Rivers Council v.  Thomas, 30 F.3d 1050 (9th Cir.  1994)
    and Silver v.  Thomas, 924 F.  Supp.  976 (D.  Ariz.  1995).

       DIFFERING JUDICIAL
       INTERPRETATIONS HAVE CREATED
       CONFLICTING REQUIREMENTS
    ---------------------------------------------------------- Chapter 6:2

    Additionally, through differing judicial interpretations of the same
    statutory requirements, the courts have sometimes established
    conflicting requirements.  For instance, three federal circuit courts
    of appeals have held that the approval of a forest plan represents a
    decision that can be judicially challenged and prohibited from being
    implemented.\2 Conversely, two other federal circuit courts of
    appeals have held that a forest plan does not represent such a
    decision and that only a project can be judicially challenged, at
    which time the adequacy of the plan's treatment of larger-scale
    environmental issues arising in the project can be reconsidered.\3

    Federal circuit courts have also differed on the applicability of
    NEPA to the designation of critical habitat for species listed as
    endangered or threatened under ESA.\4

    In proposing revisions to its planning regulations in April 1995,\5
    the Forest Service attempted to clarify its position that a forest
    plan does not represent a decision and that only a project can be
    judicially challenged.  According to the proposed rule, forest plans
    are used to allocate lands and resources within a plan's area through
    management prescriptions consisting of goals, objectives, standards,
    and guidelines.  Hence, forest plans do not compel the agency to
    undertake any specific projects, but only, in the Forest Service's
    view, establish limitations on actions that may be authorized later
    when project-level decisions are made.  In contrast, during a
    project, according to the Forest Service, site-specific activities
    are authorized and the agency reaches the threshold of an
    irreversible and irretrievable commitment of resources.  Thus, for
    the Forest Service, challenges to the agency's compliance with NEPA
    are appropriate only at the project level.

    --------------------
    \2 Sierra Club v.  Thomas, 105 F.3d 248 (6th Cir.  1997); Sierra Club
    v.  Marita, 46 F.3d 606 (7th Cir.  1995); and Idaho Conservation
    League v.  Mumma, 956 F.2d 1508 (9th Cir.  1992).

    \3 Sierra Club v.  Robertson, 28 F.3d 753 (8th Cir.  1994) and
    Wilderness Society v.  Alcock, 83 F.3rd 386 (11th Cir.  1996).

    \4 Douglas County v.  Babbitt, 48 F.3d 1495 (9th Cir.  1995) (NEPA
    does not apply) and Catron County v.  U.S.  Fish & Wildlife, 75 F.3d
    1429 (10th Cir.  1996) (NEPA applies).

    \5 60 Fed.  Reg.  18886 (Apr.  13, 1995).

       DIFFERENT APPROACHES TO
       PROTECTING RESOURCES HAVE BEEN
       DIFFICULT TO RECONCILE
    ---------------------------------------------------------- Chapter 6:3

    Environmental laws generally address individual resources, such as
    endangered and threatened species, water, and air.  Conversely, the
    Forest Service's planning statutes, including the National Forest
    Management Act (NFMA), generally establish objectives for multiple
    resources, such as sustaining diverse plant and animal communities,
    securing favorable water flow conditions, and preserving wilderness.
    These different approaches to achieving similar environmental
    objectives--protecting individual resources versus protecting
    multiple resources--have sometimes been difficult for the Forest
    Service and other federal agencies to reconcile, at least in the
    short term.

    An interagency task force chaired by the Council on Environmental
    Quality (CEQ) reported in 1995 that under some circumstances, the
    needs of a single species listed under ESA may be inconsistent or
    difficult to reconcile in the short term with the requirements for
    maintaining the forests' long-term health and sustaining diverse
    plant and animal communities (biological diversity) established under
    NFMA.\6 Maintaining the forests' long term health and sustaining
    biological diversity may also be difficult to reconcile in the short
    term with requirements to protect other resources, such as air and
    water.

    For example, nature relies on periodic small wildfires to create a
    variety of habitats that sustain diverse plant and animal
    communities.  However, until recently, a federal policy required the
    suppression of all fires on federal lands.\7 As a result, fuels and
    abnormally dense undergrowth have accumulated in many forests.  The
    Forest Service now plans to prescribe burning to restore the forests'
    health and biological diversity and avoid unnaturally catastrophic
    fires.  However, as noted by the Congressional Research Service in
    1996, the standards for air quality required under the Clean Air Act
    may at times preclude the Forest Service from achieving this goal by
    limiting the timing, location, and amount of the prescribed
    burning.\8 In addition, the standards for water quality required
    under the Clean Water Act and the requirement for conserving species
    listed under ESA can limit the timing, location, and amount of the
    prescribed burning because soils from burned areas wash into streams,
    modifying species' habitats.  Forest Service officials in the
    agency's Intermountain Region and in headquarters told us that they
    cannot implement recently proposed increases in prescribed burning
    and still meet the standards for air and water quality.

    The Congressional Research Service's 1996 report also noted that
    salvage timber sales may sometimes be needed in combination with
    prescribed burning and other activities to improve the forests'
    health.  However, water quality standards required under the Clean
    Water Act may at times limit salvage sales.  For example, according
    to officials on the Idaho Panhandle national forests, concerns about
    water quality in a particular watershed had reduced a salvage sale's
    achievement of its objectives of improving the forests' health.

    --------------------
    \6 The Ecosystem Approach:  Healthy Ecosystems and Sustainable
    Economies, Vol.  II, Implementation Issues, Report of the Interagency
    Ecosystem Management Task Force (Nov.  1995).

    \7 Federal Fire Management:  Limited Progress in Restarting the
    Prescribed Fire Program (GAO/RCED-91-42, Dec.  5, 1990).

    \8 Forest Health:  Overview, Congressional Research Service (5-548
    ENR, revised June 7, 1996).

       A SYSTEMATIC AND COMPREHENSIVE
       ANALYSIS OF THE LAWS IS NEEDED
    ---------------------------------------------------------- Chapter 6:4

    Adequately addressing statutory requirements to consider new
    information and events, different judicial interpretations of the
    same statutory requirements, and different approaches to achieving
    similar environmental objectives under various planning and
    environmental laws would require a systematic and comprehensive
    analysis of the laws to avoid making changes that would entail
    unintended consequences for the future.

    A report\9 on a workshop held at the Yale School of Forestry and
    Environmental Studies in October 1993 supports the concerns expressed
    by Forest Service and other Agriculture officials.  The over 100
    resource managers, scientists, and policy analysts--representing
    federal and state agencies, major corporations, and environmental
    organizations--concluded that the current statutory framework is a
    "spotty patchwork" of many often competing, contradictory, and/or
    conflicting laws and regulations involving multiple governments,
    agencies, and purposes.  Similarly, one federal court has described
    the current framework of laws as a "crazy quilt of apparently
    mutually incompatible statutory directives."\10

    In addition, as examples in the preceding discussion have shown,
    unintended consequences have often been the rule rather than the
    exception in implementing planning and environmental statutes
    affecting federal land management.  Therefore, any proposal to change
    the current statutory framework would require careful consideration
    to ensure that no unintended consequences would occur.  In
    particular, potential gains in efficiency and effectiveness would
    need to be balanced against the policy reasons that led to the
    existing framework of laws and organizational structure.

    For example, disagreements between the Forest Service and federal
    regulatory agencies--including the Fish and Wildlife Service, the
    National Marine Fisheries Service, the Environmental Protection
    Agency (EPA), and the U.S.  Army Corps of Engineers--on whether and
    how the requirements of environmental laws and regulations can best
    be met sometimes delay Forest Service plans and projects.  These
    disagreements often stem from differing evaluations of environmental
    effects and risks, which in turn reflect the agencies' disparate
    missions and responsibilities.  For instance, the Forest Service may
    be willing to accept a greater level of risk to the recovery of a
    threatened or endangered species under its multiple-use and
    sustained-yield mandate than would the Fish and Wildlife Service or
    the National Marine Fisheries Service, both of which are charged
    unambiguously with conserving and protecting species threatened with
    extinction.  For example, disagreements over protecting the spawning
    habitat of salmon in the Pacific Northwest and protecting endangered
    species' habitat in the Tongass National Forest in Alaska have
    resulted in delays at both the plan and project levels.

    Therefore, even though transferring the responsibility for
    environmental compliance from the regulatory agencies to the Forest
    Service might help to expedite the implementation of forest plans and
    projects, any potential gains in efficiency from such transfers would
    need to be weighed against the policy reasons that led originally to
    separating the responsibility for managing the nation's forests for
    multiple uses from the responsibility for ensuring regulatory
    compliance with environmental and other laws.  Moreover, other steps
    could be taken to expedite the implementation of forest plans and
    projects, including the consolidation of responsibility for
    environmental compliance in one federal agency.  Such consolidation
    would provide the Forest Service and other federal land management
    agencies with what is sometimes referred to as "one-stop-shopping."

    Furthermore, even if proposed changes to the current framework of
    laws were limited to legislation affecting the Forest Service,
    decisionmakers would need to consider the consequences of these
    changes for other federal land management agencies.  Changes intended
    to help speed the implementation of the Forest Service's plans and
    projects could have a rippling effect throughout the federal land
    management structure.  For instance, in developing a plan or reaching
    a project-level decision, the Forest Service or the Bureau of Land
    Management must assess the cumulative impact of the decision when its
    effects are added to those of other decisions occurring on both
    federal and nonfederal lands.  Thus, exempting the Forest Service
    from, or granting it waivers to, environmental laws to increase the
    levels of goods and services produced on national forests could
    require countervailing reductions in the levels of goods and services
    produced on lands managed by the Bureau.

    Some Forest Service officials, including the Chief, believe that an
    independent, bipartisan commission similar to the Public Land Law
    Review Commission\11 may need to be established to thoroughly review
    the current statutory framework.  In its 1970 report to the President
    and the Congress, the Commission recommended changes to laws.\12
    Similarly, in its response to a 1996 survey on land management by the
    Western Governors' Association, the Forest Service stated that "a
    serious and bipartisan review" of the laws might "provide new
    insights and valuable ideas," and a draft report by the Forest
    Service and Agriculture's Office of General Counsel suggested that a
    legislative statement "outlining how ESA, NEPA, NFMA, etc., fit
    together in a uniform coherent manner" might be beneficial.

    --------------------
    \9 Building Partnerships for Ecosystem Management on Forest and Range
    Lands in Mixed Ownership, Workshop Synthesis, Forest Policy Center
    (Oct.  22-24, 1993).

    \10 United States v.  Brunskill, No.  S-82-666-LKK, unpublished op.
    (E.D.  Cal.  Nov.  8, 1984) aff'd, 792 F.2nd 938 (9th Cir.  1986).

    \11 The Public Land Law Review Commission was a bipartisan group
    established by the Congress in 1964 with members appointed by both
    the President and the Congress.  This commission was tasked with
    conducting a thorough investigation of federal land management and
    reporting its findings to the President and the Congress.

    \12 One Third of the Nation's Land:  A Report to the President and to
    the Congress by the Public Land Law Review Commission (Washington
    D.C.:  June 1970).

       LACK OF AGREEMENT ON THE FOREST
       SERVICE'S MISSION PRIORITIES
       HAS DELAYED NEEDED ANALYSIS OF
       THE LAWS
    ---------------------------------------------------------- Chapter 6:5

    We have observed that no significant legislation was enacted on the
    basis of the Public Land Law Review Commission's proposals, in part
    because the proposals were not supported by a solid consensus for
    change.\13 The Forest Service's decision-making process is clearly
    broken and in need of repair, and a consensus for statutory change
    appears to be growing to improve the efficiency and effectiveness of
    the process.  However, any legislation that may be needed to clarify
    or modify the Congress's intent and expectations requires that the
    Forest Service and the Congress reach agreement on the agency's
    long-term strategic goals, on the uses that the agency should
    emphasize under its broad multiple-use and sustained-yield mandate,
    and on how it is to resolve conflicts or make choices among competing
    uses on its lands.  (See ch.  4.)

    Without agreement on the Forest Service's mission priorities, we see
    distrust and gridlock prevailing in any effort to streamline the
    agency's statutory framework.  For instance, during his Senate
    confirmation hearing in April 1995, the Secretary of Agriculture
    pledged to work with the Congress to identify statutory changes to
    improve the processes for implementing the Forest Service's mission.
    The Forest Service suggested options for changing the current
    statutory framework in 1995.  However, the Secretary has not sent to
    the Congress either the agency's suggested options or his analysis.
    Administration officials have said that they are hesitant to suggest
    changes to the procedural requirements of planning and environmental
    laws because they believe that the Congress may also make substantive
    changes to the laws with which they would disagree.

    Similarly, a draft Senate bill--entitled the Public Land Management
    Responsibility and Accountability Restoration Act--was circulated
    late in 1996.  The draft bill is designed to provide the Forest
    Service and the Bureau of Land Management with the authority and
    ability to effectively manage their lands in accordance with the
    principles of multiple use and sustained yield and for other
    purposes.  It would do this by supplementing the agencies' planning
    statutes and other laws that apply to lands managed by the two
    agencies.  However, some environmental groups view the bill as an
    effort to emphasize timber production over other uses on federal
    lands.  As a result, they predict that debate on the draft, if it is
    introduced as a bill, will end in a stalemate.

    --------------------
    \13 Federal Land Management:  Streamlining and Reorganization Issues
    (GAO/T-RCED-96-209, June 27, 1996).

       CONCLUSIONS
    ---------------------------------------------------------- Chapter 6:6

    Differences in the requirements of planning and environmental laws,
    enacted primarily during the 1960s and 1970s, produce inefficiency
    and ineffectiveness in the Forest Service's and other federal
    agencies' decision-making.  Adequately addressing these differences
    would require a systematic and comprehensive analysis of the laws to
    avoid making changes that would entail unintended consequences for
    the future.  Moreover, for this analysis to result in changes to
    laws, there must be a solid consensus for change.  However, such a
    consensus depends on reaching agreement on the Forest Service's
    long-term strategic goals, as well as on the uses that the agency is
    to emphasize under its broad multiple-use and sustained-yield mandate
    and on how it is to resolve conflicts or make choices among competing
    uses on its lands.

    THE FOREST SERVICE'S
    DECISION-MAKING PROCESS
    =========================================================== Appendix I

    Decision-making in the Forest Service is a complex, multilevel
    process involving other federal agencies; state, local, and tribal
    governments; and the public.  Many laws and regulations govern this
    process, and still more variables affect the final outcome--a
    decision to implement a project.  Projects are "on the ground"
    activities, such as harvesting timber, restoring species' habitats,
    and constructing campsites.  The Forest Service's decision-making
    process consists of a series of steps linking national, regional,
    forest, and district decision-making.  This process becomes
    increasingly specific as planning progresses from the national to the
    forest and district level.  Planning is iterative, requiring
    continuous monitoring, evaluation, and adjustment as information from
    the forest level flows up to the national level and down to the
    forest and district level.  The four decision-making levels
    correspond to the agency's four administrative levels (see fig.
    I.1).

       Figure I.1:  Forest Service
       Decision Levels

       (See figure in printed
       edition.)

    At the national level, the Forest and Rangeland Renewable Resources
    Planning Act of 1974 (known as RPA) establishes a long-range
    strategic planning process through which the Forest Service reviews
    the condition of the country's long-range renewable resources.
    First, every 10 years the Forest Service conducts a comprehensive
    assessment of the nation's renewable resources, including timber,
    range, water, wildlife and fish, and wilderness.  The assessment
    examines resource conditions, trends in supply and demand, and
    opportunities to invest in resource production.  Projections are made
    of future supply and demand for each resource for at least four
    decades.  On the basis of these projections, the assessment
    identifies the potential opportunities to meet the nation's future
    needs.  Then, every 5 years, the Forest Service prepares a program to
    respond to the trends and opportunities identified in the assessment.
    The program recommends a level of future outputs and associated costs
    and covers at least four decades.  The assessment and the program are
    transmitted to the Congress along with a presidential statement of
    policy, which indicates the President's intention to implement the
    program through the annual budgeting process.  The Congress may
    accept or revise the statement of policy.  Once approved, the
    statement of policy and recommended program serve as a guide to the
    Forest Service's future planning and as a basis for future budget
    proposals.  Finally, an annual report assesses the Forest Service's
    accomplishments and progress in implementing the program.  (See fig.
    I.2.)

       Figure I.2:  RPA Planning
       Process

       (See figure in printed
       edition.)

       Source:  Office of Technology
       Assessment.

       (See figure in printed
       edition.)

    At the regional level, each of the Forest Service's nine regions is
    required by the agency's regulations to develop a regional guide.
    The primary purpose of the guide is to help link the agency's
    strategic planning at the national level, through the RPA assessment
    and program, with forests' and districts' planning at more local
    levels.  The Chief of the Forest Service assigns to each region its
    share of the level of future outputs and associated costs recommended
    in the program.  With this and other information, each region
    develops a guide to address issues best resolved at the regional
    level and to provide direction for managers in developing individual
    forest plans.  For example, a regional guide might designate a
    transportation corridor running through a number of forests or
    prescribe harvesting methods based on the biological requirements of
    tree species or forest types.  Regional guides also tentatively
    distribute resource targets among individual national forests.

    At the forest level, the National Forest Management Act of 1976
    (NFMA) requires each forest or group of small adjacent forests to
    develop a land and resource management plan, commonly called a forest
    plan.  These plans blend national and regional demands with local
    forests' capabilities and needs and serve as a basis for developing
    future budget proposals.  The plans also provide direction for
    project-level decisions--decisions about on-the-ground activities--by
    establishing goals and objectives, standards and guidelines, and
    management areas.  Goals and objectives describe the desired outcome
    of the forest plan, including the level of goods and services to be
    produced from forest resources and the resulting physical and
    biological changes.  The goals and objectives also describe the
    desired future condition of the forest (for example, after 10 and 50
    years).  The description could include the age and composition of
    tree stands, acres of roadless areas, miles of roads, and numbers and
    kinds of facilities.

    Plans also include standards and guidelines that impose limitations
    on how, when, and where activities can occur and usually protect a
    specific resource, such as streams or wildlife.  Standards and
    guidelines can apply forestwide or to specific management areas.
    Management areas are areas with similar management objectives that
    are managed in the same way, such as wilderness, old-growth wildlife
    habitat, or national forest monuments.

    In developing plans, forest planners consider a broad range of
    alternatives that, to the extent practicable, reflect the full range
    of major commodity and environmental resource uses and values that
    could be produced from a forest.  The alternatives are formulated to
    provide different ways of addressing the major public issues,
    management concerns, and resource opportunities identified during the
    planning process.  At least one alternative is designed to meet the
    forest's tentatively assigned share of the RPA program's goals;
    others have resource outputs that are above or below the RPA
    program's levels.  After alternatives have been developed and
    evaluated, a preferred alternative is selected by the forest.  The
    regional forester is responsible for approving the plan.  As figure
    I.3 illustrates, the public and outside agencies-- including federal,
    state, and local agencies; tribal governments; and others interested
    in the planning process--are consulted at several points in the
    process.  Later, if circumstances warrant, the plan may be revised.
    Depending on the scope of the revisions, the same or an abbreviated
    process may be used to amend the plan.  Plans must be revised at
    least every 15 years.

       Figure I.3:  Developing Forest
       Plans

       (See figure in printed
       edition.)

    Plans are implemented on a project-by-project basis.  Project
    decisions are usually made at the district, the lowest administrative
    level in the Forest Service.  As figure I.4 indicates, the process of
    making a project decision shares several features with the process of
    developing a forest plan.  Potential projects are identified that are
    consistent with the direction provided by the forest plan.  Through
    consultation with the public and other agencies and governments,
    issues are raised, alternatives are developed and considered, and a
    preferred alternative is chosen.

       Figure I.4:  Making Project
       Decisions

       (See figure in printed
       edition.)

    Regional guides, forest plans, and project decisions can be
    judicially and administratively challenged.  Administrative appeals
    must be exhausted before cases are brought before a court.  The
    process generally used to appeal project decisions is different from
    the one generally used to appeal major changes to plans and regional
    guides.  However, both processes provide an opportunity for the
    official who made the decision being appealed to meet informally with
    the appellants and for other interested parties and the public to
    become involved.  Figure I.5 shows the process generally used for
    appealing project decisions.

       Figure I.5:  Process for
       Appealing Project Decisions

       (See figure in printed
       edition.)

    An appeal must be filed within 45 days of a project decision.  When a
    decision is appealed, the official who made the decision (the
    responsible officer) must offer to meet with the appellant and
    attempt to informally resolve the appeal.  The responsible officer is
    often a district ranger or forest supervisor.  If this effort is not
    successful, the appeal reviewing officer, a Forest Service official
    of equal or higher grade and not otherwise involved, reviews the
    case.  On the basis of his or her assessment of the documentation
    developed by the responsible officer in reaching the decision, the
    issues raised in the appeal, and comments submitted by interested
    parties, the appeal reviewing officer makes a recommendation to the
    appeal deciding officer.  The appeal deciding officer is the Forest
    Service official responsible for rendering the final decision on an
    appeal and is generally the regional forester or his or her
    designate.  The appeal deciding officer may affirm or reverse the
    responsible official's decision, in whole or in part, and may include
    instructions for further action.

    Appeals of regional guides and national forest plans are generally
    subject to different Forest Service regulations.  Depending on the
    type of decision being appealed, appeals must be filed within 45 or
    90 days of the date specified in the legal notice announcing the
    decision.  Appeals are filed with an official at the administrative
    level above that of the official who made the decision being
    appealed.  For example, if the decision is made by a forest
    supervisor, the notice of appeal is filed with the regional forester;
    if the decision is made by a regional forester, the notice of appeal
    is filed with the Chief of the Forest Service.  If the decision is
    made by the Chief of the Forest Service, the notice of appeal is
    filed with the Secretary of Agriculture.  This is the only level of
    appeal available unless an official above the official with whom the
    appeal was filed exercises the discretion to call for a second-level
    review.

    Although decisions made at the national level provide direction for
    plan- and project level-decisions, numerous laws also have a
    substantial effect on developing and implementing these decisions.
    Chief among these are laws protecting natural, cultural and historic
    resources, including the Clean Water Act, the Clean Air Act, the
    National Historic Preservation Act, the Archeological Resources
    Protection Act, and the Migratory Bird Treaty Act.  Two of the most
    significant laws affecting the Forest Service's decision-making are
    the National Environmental Policy Act (NEPA) and the Endangered
    Species Act (ESA).

    NEPA is a procedural law.  As such, it does not establish any
    substantive standards or thresholds for permissible environmental
    effects.  Its implementing regulations require that high-quality
    environmental information be available to public officials and
    citizens before decisions are made and before actions are taken.
    NEPA requires all federal agencies, including the Forest Service, to
    prepare detailed environmental impact statements (EIS) for major
    federal actions that may significantly affect the quality of the
    human environment.  The Forest Service is required to prepare EISs
    for forest plans and some project decisions.

    The heart of an EIS is an analysis of the environmental effects of a
    proposed action and alternative actions that provides a clear basis
    for choice by the decision-maker and the public.  In preparing an
    EIS, the Forest Service (like all agencies) must consider the direct,
    indirect, and cumulative effects on the environment of the proposed
    action in conjunction with past, current, and reasonably foreseeable
    future activities on Forest Service land, other federally and
    nonfederally owned government land, and privately owned land.  If
    gaps in information about significant adverse effects exist, the
    Forest Service must identify them and describe how they will be dealt
    with.  As figure I.6 demonstrates, if the Forest Service is not sure
    whether the effects of the proposed action are "significant," it
    conducts an environmental assessment (EA) to determine whether an EIS
    is warranted.  A proposed action may also be categorically excluded
    from further analysis if the action falls into a predetermined
    category of activity that has no or minor environmental impact.

       Figure I.6:  NEPA Process

       (See figure in printed
       edition.)

    ESA requires all federal agencies, including the Forest Service, to
    ensure that their actions are not likely to jeopardize the continued
    existence of species listed as threatened or endangered or to
    adversely modify habitat critical to their survival.  To fulfill this
    requirement, the Forest Service must consult with either the Fish and
    Wildlife Service (FWS) (for freshwater and land species) or the
    National Marine Fisheries Service (NMFS) (for marine species) when a
    plan or project could affect a listed species.  The goal of this
    consultation is to identify and resolve conflicts between (1) the
    protection and enhancement of the listed species and (2) the actions
    proposed in the forest plan or project.

    The process usually begins with informal discussions and/or
    correspondence between the Forest Service and FWS/NMFS (called
    "informal consultation") to assist the Forest Service in determining
    whether formal consultation is required.  FWS/NMFS may suggest
    modifications to plans or projects to avoid adverse effects on listed
    species or critical habitat.  These modifications may require the
    Forest Service to repeat some steps in the decision-making process,
    including developing a new EIS.  The Forest Service proceeds to
    formal consultation if its actions may affect listed species or their
    habitat.  However, the Forest Service need not formally consult if
    FWS/NMFS has confirmed, during informal consultation, that the
    proposed plan or project is not likely to adversely affect the listed
    species or their habitat.  At the conclusion of the formal
    consultation, FWS/NMFS issues a "biological opinion" that reviews the
    potential effects of the proposed action on the listed species and/or
    critical habitat.  FWS/NMFS must base the opinion on the best
    available biological information.  FWS/NMFS issues a "no jeopardy"
    biological opinion if it finds that the proposed action is not likely
    to jeopardize the continued existence of the listed species or
    adversely modify their habitat.  If FWS/NMFS finds that the action
    would appreciably reduce the likelihood of the species' survival and
    recovery, it issues a "jeopardy" biological opinion.  Jeopardy
    opinions can include reasonable and prudent alternatives that define
    modifications to the Forest Service's plan or project that enable it
    to continue and still be consistent with ESA's requirements for
    protecting the species.  Following the issuance of the biological
    opinion, the Forest Service determines whether it will comply with
    the opinion or seek an exemption from the act's requirements.

       Figure I.7:  ESA Consultation
       Process

       (See figure in printed
       edition.)

    In addition to the decision-making process, the annual Forest Service
    budget has a substantial effect on the national forests' management.
    Budgets affect the total funding available to implement forest plans
    and the character of the projects implementing the plans.  Before
    Forest Service officials develop their budget requests, they receive
    instructions from Forest Service headquarters providing guidelines
    for meeting the long-term policies determined in the RPA planning
    process and for implementing forest plans to the extent practical
    within prescribed funding constraints.  Each forest then develops a
    budget estimate, basing it on the projects anticipated for the fiscal
    year being budgeted.  Because anticipated projects are based on
    forest plans, they are intended collectively to reflect an approach
    to implementing the forest plans.  However, because the Congress
    appropriates funds by resource activity, these integrated requests
    must be converted into budget requests by resource activity.  The
    budget for each resource activity is subject to modification by the
    administration and the Congress.  Following reviews by the Office of
    Management and Budget and the Congress and the enactment of an
    appropriation bill, the appropriations are allocated to the regions
    and then to the forests.  The appropriation for each resource
    activity must be converted back into multiple-use projects--not an
    easy task, because the appropriation is unlikely to provide for the
    balanced mix of resources needed to implement forest plans.

    Figures I.8 and I.9 summarize the Forest Service's decision-making
    process.  Figure I.8 combines the charts and other material discussed
    above into one summary chart, and figure I.9 graphically represents
    all the participants in the Forest Service' decision-making process.

       Figure I.8:  Summary of the
       Forest Service's
       Decision-Making Process

       (See figure in printed
       edition.)

       Figure I.9:  Participants in
       the Forest Service's
       Decision-Making Process

       (See figure in printed
       edition.)

    NATIONAL FORESTS VISITED
    ========================================================== Appendix II

    Northern Region (Region I)

    Clearwater National Forest (Idaho)
     Powell Ranger District

    Deerlodge National Forest (Montana)
     Deer Lodge Ranger District

    Flathead National Forest (Montana)
     Swan Lake Ranger District

    Rocky Mt.  Region (Region 2)

    Black Hills National Forest (South Dakota)
     Bearlodge Ranger District
     Custer-Elk Mountain Ranger District
     Harney-Pactola Ranger District
     Spearfish-Nemo Ranger District

    Southwest Region (Region 3)

    Carson National Forest (New Mexico)
     Camino Real Ranger District
     El Rito Ranger District

    Cibola National Forest (New Mexico)

    Intermountain Region (Region 4)

    Boise National Forest (Idaho)
     Cascade Ranger District
     Lowman Ranger District
     Mountain Home Ranger District

    Pacific Southwest Region (Region 5)

    Tahoe National Forest (California)
     Sierraville Ranger District

    Pacific Northwest Region (Region 6)

    Mt.  Hood National Forest (Oregon)

    Wenatchee National Forest (Washington)
     Chelan Ranger District
     Entiat Ranger District

    Southern Region (Region 8)

    Nantahala - Pisgah National Forest (North Carolina)
     French Broad Ranger District
     Toecane Ranger District

    Ouachita National Forest (Arkansas)
     Choctaw-Kiamichi-Tiak Ranger District
     Cold Springs Ranger District

    Eastern Region (Region 9)

    Chequamegon National Forest (Wisconsin)
     Glidden/Hayward Ranger District
     Park Falls/Medford Ranger District
     Washburn Ranger District

    Nicolet National Forest (Wisconsin)
     Eagle River/Florence Ranger District
     Laona and Lakewood Ranger District

    North Central Forest Experiment Station, Forestry Sciences Laboratory
    (Wisconsin)

    ORGANIZATIONS CONTACTED
    ========================================================= Appendix III

    American Forest and Paper Association, Washington, D.C.

    American Forests, Washington, D.C.

    American Institute of Biological Sciences, Washington, D.C.

    Appalachian Trail Conference, Asheville, N.C.

    Arkansas Game and Fish Commission

    Arkansas Natural Heritage Commission

    Association of Consulting Foresters of America, Inc., Bethesda, Md.

    ATOKA Engineering and Environmental Consulting, Hot Springs, Ark.

    B.A.  Mullican Lumber and Manufacturing Company, Maryville, Tenn.

    Balanced Resource Solutions, Woodbridge, Va.

    Black Hills Regional Multiple Use Coalition:  Members include
    representatives from the following organizations:

    Continental Lumber Co., Inc., Hill City, S.  Dak.
    Intermountain Forest Industries Association, Coeur
    d'Alene, Idaho
    Off Road Riders Association, Black Hawk, S.Dak.
    Pope & Talbot, Inc., Spearfish, S.Dak.
    South Dakota Trail Riders, Rapid City, S.Dak.
    Wyoming Stock Growers Association, Sundance, Wyo.

    Boardman, Suhr, Curry & Field, Madison, Wis.

    Boise Cascade, Inc., Emmett, Idaho

    Boise Cascade, Inc., La Grande, Oreg.

    Boise County Commission, Idaho City, Idaho

    California Department of Fish and Game

    California Department of Natural Resources

    California Forestry Association, Sacramento, Calif.

    California Regional Water Quality Control Board, Lahontan Region

    Carson Forest Watch, Taos, N.Mex.

    Cascade Checkerboard Project (Sierra Club), Seattle, Wash.

    Center for Market Pocesses, Inc., Fairfax, Va.

    CH2M Hill, Portland, Oreg.

    Chequamegon Area Mountain Bike Association, Cable, Wis.

    City of Salem, Oreg.

    Columbia Carolina Corporation, Old Fort, N.C.

    Confederated Tribes of the Umatilla Indian Reservation, Pendleton,
    Oreg.

    Defenders of Wildlife, Portland, Oreg.

    Defenders of Wildlife, Washington, D.C.

    Department of Forest Resources, University of Minnesota, St.  Paul,
    Minn.

    Duke City Lumber Company, Inc., Espanola, N.Mex.

    Earth Satellite Corporation, Rockville, Md.

    Eastside Ecosystem Management Project, Walla Walla, Wash.

    Ecological Society of America, Washington, D.C.

    Endangered Species Coalition, Washington, D.C.

    Environmental Law Institute, Washington, D.C.

    Environmental Policy Network, Alexandria, Va.

    Forest Conservation Council, Santa Fe, N.Mex.

    Forest Guardians, Santa Fe, N.Mex.

    Forest Inholders Guarding Habitat Together (FIGHT), Parks, Ark.

    Forest Trust, Santa Fe, N.Mex.

    Friends Aware of Wildlife Needs, Georgetown, Calif.

    Governor's Federal Forest and Resource Policy Team, Salem, Oreg.

    Great Lakes Indian Fish and Wildlife Commission, Odanah, Wis.

    Greater Ecosystem Alliance, Bellingham, Wash.

    Green Bay Packaging Inc., Morrilton, Ark.

    Hanson Environmental Consultants, Englewood, Colo.

    Huron River Watershed Council, Ann Arbor, Mich.

    Idaho Conservation League, Boise, Idaho

    Idaho Department of Fish and Game

    International Joint Commission, Detroit, Mich.

    Jim Crouch and Associates, Russelville, Ark.

    Karuk Tribe of California, Orleans, Calif.

    Labat-Anderson, Inc., Arlington, Va.

    Lac du Flambeau Band of Lake Superior Chippewa Indians, Lac du
    Flambeau, Wisc.

    Land-of-Sky Regional Council, Asheville, N.C.

    Lane County Commissioner, Eugene, Oreg.

    Las Truchas Community Representatives, N.Mex.

    Lewis and Clark College, Graduate School of Professional Studies,
    Portland, Oreg.

    Maxwell School of Citizenship and Public Affairs at Syracuse
    University, Syracuse, N.Y.

    Mead Corp., Escanaba, Mich.

    Michigan Department of Natural Resources

    Michigan State University, Department of Forestry, Lansing Mich.

    Mississippi Forestry Commission, Jackson, Miss.

    National Academy of Sciences, National Research Council, Board on
    Biology and Institute of Laboratory Animal Resources, Commission on
    Life Sciences, Washington, D.C.

    National Academy of Sciences, National Research Council, Board on
    Environmental Studies and Toxicology, Washington, D.C.

    National Association of State Foresters, Washington, D.C.

    National Audubon Society, Rapid City, S.Dak.

    National Audubon Society, Walla Walla, Wash.

    National Resource Defense Council, Washington, D.C.

    National Wildlife Federation, Portland, Oreg.

    Natural Resources Services, Eureka, Calif.

    North Carolina Council of Trout Unlimited, Asheville, N.C.

    North Carolina Wildlife Resources Commission

    Northwest Forest Resources Council, Portland, Oreg.

    Northwest Forestry Association, Portland, Oreg.

    Northwest Timber Workers Resource Council, Emmett, Idaho

    Office of the Governor, State of Idaho

    Office of the Governor, State of Oregon

    Office of the Governor, State of California

    Oregon Department of Environmental Quality

    Oregon Forest Industries Council, Salem, Oreg.

    Oregon Natural Resources Council, Portland, Oreg.

    Ouachita Watch League, Sims, Ark.

    Pacific Lumber & Shipping Co., Seattle, Wash.

    Pacific Meridian Resources, Emeryville, Calif.

    Pacific Rivers Council, Eugene, Oreg.

    Pacific Watershed Associates, Arcata, Calif.

    Paul Bunyan Snowmobile Club, Lakewood, Wisc.

    Pinchot Institute for Conservation, Washington, D.C.

    Plum Creek Timber Co., Seattle, Wash.

    Quincy Library Group, Quincy, Calif.

    Resource Issues, Inc., Wayland, Mass.

    Rocky Mountain Elk Foundation, Custer, S.Dak.

    Rogue Institute for Ecology and Economy, Ashland, Oreg.

    Save America's Forests, Washington, D.C.

    Seventh American Forest Congress, New Haven, Conn.

    Sierra Club, Nevada City, Calif.

    Sierra Club, North Carolina Chapter

    Sierra Club, Rapid City, S.Dak.

    Sierra Pacific Industries, Redding, Calif.

    Sipapu Ski Area, Vadito, N.Mex.

    Skagit County Commissioner, Mount Vernon, Wash.

    Smithsonian Institution, Biodiversity and Environmental Affairs,
    Washington, D.C.

    Society of American Foresters, Bethesda, Md.

    Southern Appalachian Forest Coalition, Asheville, N.C.

    Southern Appalachian Man and the Biosphere Project, Gatlinburg, Tenn.

    Southern Appalachian Multiple Use Council, Waynesville, N.C.

    Southern Timber Purchasers Council, Atlanta, Ga.

    Southwest Center for Biological Diversity, Tuscon, Ariz.

    Sustainable Biosphere Initiative, Washington, D.C.

    T & S Hardwood Corp., Sylva, N.C.

    The Nature Conservancy, Arlington, Va.

    The Ruffed Grouse Society, Rice Lake, Wis.

    The Willapa Institute, Seattle, Wash.

    Trinity County Planning Department, Weaverville, Calif.

    Umatilla Forest Resources Council, Walla Walla, Wash.

    Union County Commissioner, La Grande, Oreg.

    University of Arizona, Water Resources Research Center, Tuscon, Ariz.

    University of Florida, Urban and Regional Planning, Gainesville, Fla.

    University of Kansas Law School, Lawrence, Kans.

    University of Michigan, Department of Natural Resources and Forestry,
    Ann Arbor, Mich.

    University of Oregon, Labor Education and Research Center, Eugene,
    Oreg.

    University of Utah, College of Law, Salt Lake City, Utah

    University of Wisconsin, Botany Department, Madison, Wis.

    Vallecitos Community Representatives, N.Mex.

    Vilas County Forestry Department, Eagle River, Wis.

    Western Ancient Forest Campaign, Stanwood, Wash.

    Western North Carolina Alliance, Asheville, N.C.

    Western States Foundation, Washington, D.C.

    Wheelabrator Shasta Energy Company Inc., Anderson, Calif.

    Wilderness Society, Atlanta, Ga.

    Wilderness Society, Washington, D.C.

    Wildlife Management Institute, Washington, D.C.

    Wisconsin Department of Natural Resources

    WNC Pallet & Forest Products Company, Candler, N.C.

    World Resources Institute, Washington, D.C.

    (See figure in printed edition.)Appendix IV
    COMMENTS FROM THE FOREST SERVICE
    ========================================================= Appendix III

    (See figure in printed edition.)

    (See figure in printed edition.)

    (See figure in printed edition.)

    (See figure in printed edition.)

    (See figure in printed edition.)

    The following are GAO's comments on the Forest Service's letter dated
    April 21, 1997.

       GAO COMMENTS
    ------------------------------------------------------- Appendix III:1

    1.  Our report does not state that the agency's multiple-use mission
    is difficult to reconcile.  Rather, our report cites numerous
    examples of disagreements, both inside and outside the Forest
    Service, over (1) which statutorily specified uses the agency should
    emphasize and (2) how it should ensure sustainability and resolve
    conflicts among uses under its broad legal mandate to provide for
    both the multiple use and the sustained yield of resources on its
    lands.  While the agency's intention to consult with the Congress on
    its long-term strategic goals as a part of its implementation of the
    Government Performance and Results Act (GPRA) is in accord with our
    report's recommendation, as the agency's comments themselves go on to
    note, this process is not yet complete.  The ongoing disagreements,
    noted in our report, over the goals in the agency's 1995 draft
    long-term strategic plan suggest that this consultation process faces
    unresolved obstacles and that the lack of agreement on goals, needed
    for good management, has hampered the agency's efficiency,
    effectiveness, and accountability.  Thus, we do not believe that our
    report is erroneous or premature in noting the existence of
    disagreements over the agency's strategic goals.

    2.  The examples of strategic goals for implementing GPRA identified
    prospectively in the Forest Service's comments do not include, as
    does the agency's 1995 draft long-term strategic plan, the goal of
    ensuring organizational efficiency and effectiveness.  This goal is
    identified in our report as the central one for measuring the
    agency's progress in taking the actions that are needed to improve
    the agency's decision-making.  In part because the Forest Service
    needs to better integrate GPRA's processes into its own
    decision-making process, our report also suggests that the Congress
    needs to consider the costs and benefits of the Forest Service's
    developing two separate long-term strategic plans.

    3.  We agree that the ecological systems within which the Forest
    Service's management activities take place are inherently dynamic,
    and our report notes that this dynamism, among other factors, affects
    the predictability of planning outcomes.  However, our report also
    identifies several actions, suggested to enhance predictability, that
    the Forest Service has not undertaken.  These include monitoring,
    obtaining better data, and strengthening public involvement, as well
    as shortening planning periods and better linking budgets and plans.

    4.  We concur that large-scale assessments, such as that being
    undertaken in the Interior Columbia River Basin, are intended to
    address issues that transcend the boundaries of individual management
    units.  Our purpose in discussing these efforts is precisely to
    indicate that they provide a basis for applying unified direction on
    these issues across multiple land management plans.

    5.  Our report recognizes that the time for conducting some
    consultations has been reduced.  However, our report also cites an
    October 1996 interagency team's analysis and other studies that
    identify ongoing serious problems with interagency coordination.
    Additionally, our report does not attribute inefficiency in complying
    with section 7 of the Endangered Species Act to overlapping
    jurisdictions; instead, it merely states that delays in implementing
    forest plans and reaching agreement on project-level decisions have
    been caused by inadequate interagency coordination.

    6.  We agree that the stated tenets of this model are largely
    consistent with our report's findings and recommendations.  However,
    as our report states, our own observation of a field test of this
    model showed that, without adequate data--which were lacking during
    the test we observed--the model was difficult, if not impossible, to
    implement.  Moreover, as our report also notes, the Forest Service
    has decided that the implementation of the model by its field units
    will be voluntary.

    7.  We agree that the ongoing debate over how national forests should
    be managed is a healthy and important part of the democratic process.
    We also agree, both as a general rule and in this instance, that
    statutory changes should not be undertaken until after it has been
    shown that regulatory or other executive branch actions cannot
    efficiently and effectively resolve identified problems.  However,
    our report does not state that there is a growing consensus for new
    legislative mandates due to conflicting laws, nor does it recommend
    changing environmental laws.  Rather, it cites evidence of (1)
    growing concerns by several parties, both inside and outside the
    agency, over difficulties in resolving differences among the
    requirements of some statutes and (2) increasing support among a wide
    spectrum of observers for undertaking an analysis of the laws to
    identify what statutory changes, if any, may be needed.

    8.  While the Forest Service may not have exercised its full
    discretion under existing laws to correct the management and
    decision-making problems identified in our report, it does not
    identify the source of such unused discretion or indicate how
    exercising full discretion might obviate the usefulness of analyzing
    statutory provisions.  As our report notes, in recent years the
    agency has not revised its procedures for monitoring, collecting
    data, and involving the public, as its own studies have repeatedly
    suggested, to resolve problems.

    9.  Overall, we believe that implementing the actions proposed
    generally here and elsewhere in the agency's comments would improve
    the efficiency and effectiveness of its decision-making process.
    However, our report notes that although the Forest Service can and
    does identify problems, without external attention it often fails, as
    its own analysis indicates, to take corrective action.  In this case,
    for instance, we note that the agency's comments do not discuss
    either a schedule to implement the proposed improvements or a plan to
    closely monitor progress and periodically report on performance.  We
    believe both are needed to break the cycle of studying and restudying
    issues without any accountability or clear sequence of steps for
    resolving them.

    (See figure in printed edition.)Appendix V
    COMMENTS FROM THE COUNCIL ON
    ENVIRONMENTAL QUALITY
    ========================================================= Appendix III

    (See figure in printed edition.)

    (See figure in printed edition.)

    (See figure in printed edition.)

    The following are GAO's comments on the Council on Environmental
    Quality's letter dated April 17, 1997.

       GAO COMMENTS
    ------------------------------------------------------- Appendix III:2

    1.  GAO agrees with the Council on Environmental Quality (CEQ) that
    (1) differences among the cultures, organizations, and institutional
    goals of various federal agencies, as well as the substantive nature
    of their underlying missions, require the Council's regulations
    implementing the act to be generic in nature and (2) regulatory
    changes often need to be tailored specifically to the agencies'
    individual processes.  However, the thrust of GAO's recommendation to
    the Council's Chair is intended to ensure that the Council's planned
    multiyear reinvention effort does not prematurely or arbitrarily
    close off options for improving the efficiency and effectiveness of
    the act's implementation across federal agencies' administrative
    boundaries and jurisdictions.

    2.  We agree that defining the optimal level of decision-making and
    analysis for every federal agency and for all types of actions in a
    single rulemaking would be problematic, and our report does not
    recommend such an effort.  Rather, we believe that CEQ is in the best
    position to determine, on the basis of the findings of its
    reinvention analysis, the manner and number of additional rulemakings
    or guidance issuances under the National Environmental Policy Act
    (NEPA) that would best meet the needs identified in our report.

    3.  We agree that the examples cited by CEQ of its work with other
    agencies indicate many differences in the missions, issues, and
    circumstances these agencies face.  However, we also note several
    points that these streamlining and analytical efforts have in common,
    such as simplified and improved public participation, expanded
    categorical exclusions, and reduced duplication of effort, which our
    report identifies as improvements also needed in CEQ's work with the
    Forest Service.  Our recommendation that CEQ consider additional
    guidance and rulemaking is directed to resolving these problems,
    which affect many agencies--not to addressing problems that are
    unique to particular agencies.

    4.  We agree that not all proposed changes to the Forest Service's
    regulations for implementing NEPA should be applied "across the board
    to all other federal agencies." However, our report does not suggest
    this.  Rather, it suggests that CEQ needs to ensure consistent
    treatment under NEPA of the same or related issues arising among
    multiple land management agencies operating in the same geographic
    areas, instead of pursuing a disaggregated agency-by-agency approach.
    This same consideration applies to CEQ's disaggregated
    'sector-by-sector' approach mentioned in the third paragraph of CEQ's
    comments, since interactions among separate activities that disturb
    soil, vegetation, or wildlife habitat (e.g., timber harvesting,
    grazing, or oil and gas development) in the same geographic area
    (e.g., the same watershed) need to be considered under NEPA, as does
    their cumulative impact.

    5.  We have modified the language in our draft report to state more
    clearly that a potential weakness of such voluntary broad-scale
    analyses is that agencies would not be able to tier their
    site-specific decisions to such analyses under NEPA.

    6.  We do not recommend precise changes to regulations or guidance to
    improve interagency coordination or address other issues because we
    believe such changes are better left to CEQ to determine on the basis
    of its own internal study and evaluation of the outside views
    solicited during its effort to reinvent federal agencies'
    implementation of NEPA.

    7.  We recognize that CEQ already has regulations and guidance
    requiring cooperative consultation among agencies before analyses are
    prepared, as well as addressing other aspects of interagency
    coordination.  However, our report points out that these regulations
    and guidance are often not followed, and our recommendation calls on
    CEQ to make its directives clear and precise enough to ensure that
    this does not continue.

    8.  We agree that a common set of data would not be appropriate for
    all scales of decision-making and recognize that different data may
    be applicable to different scales.  However, our report--which cites,
    among other authorities, the 1995 findings of the interagency task
    force chaired by CEQ--emphasizes that CEQ needs to clarify what
    different kinds of data are needed at which scales and how the data
    should be related to different types of tiered decisions.

    9.  We do not disagree that CEQ's current resources may not be
    sufficient to adequately implement our recommendation.  However,
    although our report cites the 1996 study of CEQ's role prepared for
    the Henry Jackson Foundation, which noted that CEQ needed additional
    resources to adequately carry out its responsibilities under NEPA, an
    analysis of such needs was beyond the scope of our review.
    Additionally, our report does not recommend that CEQ itself
    necessarily collect all ecological and socioeconomic data.  Rather,
    it says CEQ should identify what data are needed and includes the
    option that CEQ assign others to collect the data as appropriate.
    Finally, as our report notes, the Forest Service's internal
    reengineering team report indicated that the establishment of
    centralized or jointly administered databases would ultimately reduce
    costs by eliminating duplication of effort among and within agencies.

    MAJOR CONTRIBUTORS TO THIS REPORT
    ========================================================== Appendix VI

    ENERGY, RESOURCES, AND SCIENCE
    ISSUES

    Charles S.  Cotton
    Alan J.  Dominicci
    Brian W.  Eddington
    Charles T.  Egan
    Elizabeth R.  Eisenstadt
    Chester M.  Joy

    OFFICE OF THE GENERAL COUNSEL

    Doreen Stolzenberg Feldman
    Alan R.  Kasdan

    *** End of document. ***