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



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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



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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

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