Ecosystem Planning: Northwest Forest and Interior Columbia River Basin
Plans Demonstrate Improvements in Land-Use Planning (Letter Report,
05/26/99, GAO/RCED-99-64).
Pursuant to a congressional request, GAO reviewed the Forest Service's
and the Bureau of Land Management's (BLM) efforts to implement two
ecosystem-based studies--the Northwest Forest Plan and the Interior
Columbia Basin Ecosystem Management Project, focusing on: (1) the extent
to which each effort has addressed long-standing planning deficiencies;
(2) whether the agencies encountered the delays and significant costs
that have been characteristic of previous planning efforts; and (3) the
effect that the plans have had, or are expected to have, on the quantity
and quality of timber sold from federal lands covered by the plans.
GAO noted that: (1) both the process used to develop and implement the
Northwest Forest Plan and the process being used to develop a plan to
manage federal lands in the interior Columbia River basin address many
of the long-standing planning deficiencies that have contributed to
delays, increased costs, and unmet objectives in other land management
plans; (2) the Forest Service and BLM completed the Northwest Forest
Plan expeditiously and at a relatively low cost, while the interior
Columbia River basin plan has taken much longer and cost much more than
originally expected and has not yet been approved; (3) the Northwest
Forest Plan was developed in 1 year at a cost of about $3.5 million; (4)
this was a timely and cost-effective effort compared with past national
forest planning efforts that took from 3 to 10 years to complete and, in
the Pacific Northwest, cost between $5 million and $8 million even
though they covered much smaller areas; (5) the timeliness of the plan
was, in part, a function of the fact that the agencies had been
gathering data on the old-growth forest habitat of the northern spotted
owl for many years; (6) although the agencies' 5-year effort to develop
a plan for the interior Columbia River basin has overcome some
long-standing deficiencies, it has not yet led to a final plan; (7) the
ongoing project has already taken 2-1/2 years longer and, at $41
million, cost $10 million more than anticipated; (8) some of the delays
and higher costs to date have occurred because the agencies
underestimated the time and effort required to address the ecological
diversity and broad array of land management issues that exist in the
interior Columbia River basin; (9) GAO also believes that their
originally proposed alternatives did not give adequate information to
stakeholders on how and with what effect the alternatives would be
implemented; (10) timber harvests have declined significantly since the
1980s and will likely remain at current levels under the Northwest
Forest Plan; (11) existing laws have resulted in less federal land being
available for timber production and less timber being produced from the
land that is available; (12) moreover, the Forest Service and BLM
overestimated the volume of timber to be harvested under their original
preferred management alternative for federal lands in the interior
Columbia River basin; and (13) as a result, the agencies created
unrealistic expectations for relatively high timber harvests that would
probably not have occurred.
--------------------------- Indexing Terms -----------------------------
REPORTNUM: RCED-99-64
TITLE: Ecosystem Planning: Northwest Forest and Interior Columbia
River Basin Plans Demonstrate Improvements in Land-
Use Planning
DATE: 05/26/99
SUBJECT: Timber sales
Environmental monitoring
Forest management
Interagency relations
Schedule slippages
Wildlife conservation
Strategic planning
Environmental policies
Land management
Cost overruns
IDENTIFIER: Pacific Northwest Forest Plan
Interior Columbia Basin Ecosystem Management Project
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Cover
================================================================ COVER
Report to Congressional Requesters
May 1999
ECOSYSTEM PLANNING - NORTHWEST
FOREST AND INTERIOR COLUMBIA RIVER
BASIN PLANS DEMONSTRATE
IMPROVEMENTS IN LAND-USE PLANNING
GAO/RCED-99-64
Ecosystem Planning
(141095)
Abbreviations
=============================================================== ABBREV
BLM - Bureau of Land Management
GAO - General Accounting Office
Letter
=============================================================== LETTER
B-281830
May 26, 1999
The Honorable Frank Murkowski
Chairman, Committee on Energy
and Natural Resources
United States Senate
The Honorable Don Young
Chairman, Committee on Resources
House of Representatives
The Honorable Larry Combest
Chairman, Committee on Agriculture
House of Representatives
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 has often failed to achieve its
planned objectives.\1 Inefficiency and waste within the process have
already cost taxpayers hundreds of millions of dollars.\2
Difficulties in addressing ecological issues that transcend the
Forest Service's administrative boundaries and jurisdiction have
contributed to the inefficiency in developing, and ineffectiveness in
implementing, forest as well as other federal land management
plans.\3
Traditionally, the Forest Service, the Department of the Interior's
Bureau of Land management (BLM), and other federal land management
agencies developed plans to manage federal resources independently
and focused mainly on the resources within the administrative
boundaries of individual national forests, parks, and other federal
land management units. These planning efforts often failed to
adequately consider ecological issues that transcend administrative
boundaries--such as issues concerning watersheds\4 or the habitats of
wide-ranging species, including migratory birds, bear, and salmon.
The agencies' past planning efforts also suffered from other
long-standing deficiencies, including (1) inadequate involvement by
other federal agencies and the public, (2) a lack of comparable
environmental and socioeconomic data, (3) inadequate monitoring to
determine the effects of past management decisions, and (4) a lack of
accountability for time and costs.
In the early 1990s, the Forest Service and BLM both announced that
they would adopt a management approach that focuses on ecosystems.
We have reported on ecosystem management as an approach and have
concluded that specific steps are necessary for its successful
implementation. These include (1) delineating ecosystems, (2)
understanding the ecology of ecosystems, (3) making management
choices, and (4) adapting management to new information.
Recently, the Forest Service and BLM have begun testing the
efficiency and effectiveness of using broad-scoped, ecosystem-based
studies to analyze ecological issues that transcend their
jurisdictions and to collaborate on plans for federal land management
units throughout large ecological regions defined by geophysical
features, such as watersheds, or the habitats of wide-ranging
species, such as the northern spotted owl. Two of the largest of the
agencies' ecosystem-based studies--a July 1993 plan,\5 the Northwest
Forest Plan (see app. I), and an ongoing planning effort, the
Interior Columbia Basin Ecosystem Management Project (see app.
II)--are intended to provide direction for managing about 90 million
acres of federal land in all or parts of eight northwestern states.
Concerned about the potential costs, timeliness, and effectiveness of
broad-scoped, ecosystem-based studies, you asked us to examine the
two planning efforts. In this report, we discuss (1) the extent to
which each effort has addressed long-standing planning deficiencies,
(2) whether the agencies encountered the delays and significant costs
that have been characteristic of previous planning efforts, and (3)
the effect that the plans have had, or are expected to have, on the
quantity and quality of timber sold from federal lands covered by the
plans.
--------------------
\1 Forest Service Decision-Making: A Framework for Improving
Performance (GAO/RCED-97-71, Apr. 29, 1997) and Tongass National
Forest: Lack of Accountability for Time and Costs Has Delayed Forest
Plan Revision (GAO/T-RCED-97-153, Apr. 29, 1997).
\2 See, for example, Forest Service: Lack of Financial and
Performance Accountability Has Resulted in Inefficiency and Waste
(GAO/T-RCED/AIMD-98-135, Mar. 26, 1998).
\3 Forest Service Decision-Making: A Framework for Improving
Performance (GAO/RCED-97-71, Apr. 29, 1997).
\4 A watershed is an area of land in which all surface water drains
to a common point. A watershed can range from less than 100 acres
drained by a single stream to many thousands of acres drained by
hundreds of smaller streams that ultimately form one stream or river.
\5 W. Clinton and A. Gore, Jr., The Forest Plan for a Sustainable
Economy and a Sustainable Environment (July 1, 1993).
RESULTS IN BRIEF
------------------------------------------------------------ Letter :1
Both the process used to develop and implement the Northwest Forest
Plan and the process being used to develop a plan to manage federal
lands in the interior Columbia River basin address many of the
long-standing planning deficiencies that have contributed to delays,
increased costs, and unmet objectives in other land management plans.
For example, (1) federal interagency coordination has improved; (2)
opportunities for public involvement have improved; (3) scientific
assessments and analyses have generated better environmental and
socioeconomic data for more informed management decisions, and (4)
processes have been or will be established to monitor the effects of
decisions and adapt management to new information.
The Forest Service and BLM completed the Northwest Forest Plan
expeditiously and at a relatively low cost, while the interior
Columbia River basin plan has taken much longer and cost much more
than originally expected and has not yet been approved. The
Northwest Forest Plan was developed in 1 year at a cost of about $3.5
million. This was a timely and cost-effective effort compared with
past national forest planning efforts that took from 3 to 10 years to
complete and, in the Pacific Northwest, cost between $5 million and
$8 million even though they covered much smaller areas. The
timeliness of the plan was, in part, a function of the fact that the
agencies had been gathering data on the old-growth forest habitat of
the northern spotted owl for many years. In addition, the federal
court injunctions on timber sales created a sense of urgency and
focus. The result was a plan that provides the agencies' field
managers with direction for implementation and sets standards for
holding them accountable. Although the agencies' 5-year effort to
develop a plan for the interior Columbia River basin has overcome
some long-standing deficiencies, it has not yet led to a final plan.
The ongoing project has already taken 2-1/2 years longer and, at $41
million, cost $10 million more than anticipated. Some of the delays
and higher costs to date have occurred because the agencies
underestimated the time and effort required to address the ecological
diversity and broad array of land management issues that exist in the
interior Columbia River basin. Additional delays and costs are being
incurred because the agencies are developing one or more new
management alternatives in response to public and congressional
criticism of their originally proposed draft management
alternatives--including their preferred alternative. We also believe
that their originally proposed alternatives did not give adequate
information to stakeholders on how and with what effect the
alternatives would be implemented.
Timber harvests have declined significantly since the 1980s and will
likely remain at current levels under the Northwest Forest Plan.
Existing laws, including the Endangered Species Act, and their
implementing regulations and judicial interpretations, have resulted
in less federal land being available for timber production and less
timber being produced from the land that is available. Moreover, the
Forest Service and BLM overestimated the volume of timber to be
harvested under their original preferred management alternative for
federal lands in the interior Columbia River basin. As a result, the
agencies created unrealistic expectations for relatively high timber
harvests that would probably not have occurred, largely because of
regulatory agencies' concerns over the impact of harvests on natural
resources and shortfalls in funding to implement the plan.
BACKGROUND
------------------------------------------------------------ Letter :2
The federal government owns about 30 percent (650 million acres) of
the nation's total surface area. Together, the Forest Service and
BLM manage about 70 percent of all federal lands. The Forest Service
manages about 192 million acres of land, including about one-fifth of
the nation's forestlands, through three levels of field management--9
regional offices, 123 forest offices, and about 600 district offices.
Laws guiding the management of the 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 agency 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 required 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. In addition, the Forest Service is
required by its guidance and regulations to consider the production
of nonrenewable subsurface resources--such as oil, gas, and hardrock
minerals\6 --in its planning.
BLM manages almost 264 million acres of land, including about 177
million acres located mainly in the western United States and about
87 million acres in Alaska, through three levels of field
management--12 state offices that oversee district and resource area
offices.\7 BLM also manages the mineral estate that underlies almost
300 million acres managed by other agencies, including the Forest
Service. The Federal Land Policy and Management Act of 1976 requires
the agency to manage its lands for multiple uses and sustained yield.
Under the act, multiple uses include recreation; range; timber;
minerals; watersheds; fish and wildlife; and natural scenic,
scientific, and historic values.
The Forest Service and BLM must comply with the requirements of the
National Environmental Policy Act of 1969. This act 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. The act requires that a federal agency prepare a detailed
environmental impact statement for every major federal action that
may significantly affect the quality of the human environment.
Environmental impact statements are 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 making decisions to implement projects,\8 the
Forest Service and BLM 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. In particular, section 7 of the
Endangered Species Act generally prohibits federal agencies from
taking actions in pursuit of their primary missions, such as timber
production, if those actions would put threatened or endangered
species at risk. When proposing a project, a federal agency is
prohibited from taking an action that would jeopardize the existence
of threatened or endangered species or adversely modify designated
critical habitat.
Several federal regulatory agencies are responsible for enforcing
environmental laws and regulations. For example, the Department of
the Interior's Fish and Wildlife Service and the Department of
Commerce's National Marine Fisheries Service share responsibility for
ensuring the protection and recovery of plant and animal species
listed as threatened or endangered under the Endangered Species Act.
The Environmental Protection Agency 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).
In April and July 1993, the President directed the development of
what would become, respectively, the Northwest Forest Plan and the
Interior Columbia Basin Ecosystem Management Project. The Northwest
Forest Plan was developed in response to court injunctions that
barred the Forest Service and BLM from selling timber harvested in
the range of the northern spotted owl, which was listed as a
threatened species in 1990. The Northwest Forest Plan includes two
components that focus on forest management and economic development.
The first component includes a regional land management plan that
provides management direction for the 22.3 million acres of land
managed by the Forest Service and BLM in the range of the northern
spotted owl. (See fig. 1.) The land management plan's development
began with a scientific assessment by six federal agencies that
described current and desired ecological conditions within the owl's
range.\9 The plan was completed when the Secretaries of Agriculture
and the Interior approved it in April 1994. The plan is currently
being implemented. The second component of the Northwest Forest
Plan, an economic assistance program aimed at helping the region
adjust to changes in federal forest management, is not discussed in
this report.
Figure 1: The Geographical
Boundaries of the Northwest
Forest Plan and of the Interior
Columbia Basin Ecosystem
Management Project
(See figure in printed
edition.)
Sources: Forest Service and
BLM.
(See figure in printed
edition.)
In July 1993, the President also directed the Forest Service to
develop a regional land management plan for national forests in
Oregon and Washington east of the crest of the Cascade Mountains.
The plan is being developed to avoid conflicts of the sort that
prompted the Northwest Forest Plan. In January 1994, the Forest
Service and BLM agreed to expand the scope of the plan to include all
lands managed by BLM in eastern Oregon and Washington. (See the
Eastside Planning area in fig. 1.) In July 1994, the two agencies
further expanded the project to include their lands in much of Idaho,
western Montana, and small portions of Nevada, Wyoming, and Utah.
(See the Upper Columbia River Basin planning area in fig. 1.) The
total planning effort encompasses about 72 million acres of federal
land and is known as the Interior Columbia Basin Ecosystem Management
Project. In June 1997, the agencies released a set of draft
management alternatives, including their preferred alternative, for
public comment. In October 1998, responding to congressional and
public criticisms, the Secretaries of Agriculture and the Interior
announced their decision to develop one or more new draft
alternatives.
--------------------
\6 Hardrock minerals include gold, silver, lead, iron, and copper.
\7 During 1999, BLM is planning to streamline its organizational
structure by combining its district and resource area offices into
field offices.
\8 Projects are on-the-ground activities, such as harvesting timber,
restoring species' habitats, and constructing campsites.
\9 The six federal agencies were the Forest Service, BLM, the Fish
and Wildlife Service, the National Park Service, the National Marine
Fisheries Service, and the Environmental Protection Agency.
THE FOREST SERVICE AND BLM HAVE
ADDRESSED MANY LONG-STANDING
PLANNING DEFICIENCIES
------------------------------------------------------------ Letter :3
During the past 5 fiscal years, we have issued reports identifying
long-standing deficiencies in federal land management decision-making
generally and in the Forest Service's decision-making
particularly.\10 These deficiencies include a lack of (1) adequate
involvement in the decision-making process by other federal agencies
and the public, (2) comparable environmental and socioeconomic data
among agencies, and (3) monitoring to determine the effects of past
management decisions. These deficiencies have increased, and could
continue to increase, the time and costs needed for any federal land
management agency to reach a decision at any organizational level.
The processes used to develop and implement the Northwest Forest Plan
and to develop a plan for managing federal lands in the interior
Columbia River basin address these deficiencies.
--------------------
\10 Forest Service Decision-Making: A Framework for Improving
Performance (GAO/RCED-97-71, Apr. 29, 1997); Tongass National
Forest: Lack of Accountability for Time and Costs Has Delayed Forest
Plan Revision (GAO/T-RCED-97-153, Apr. 29, 1997); Forest Service:
Lack of Financial and Performance Accountability Has Resulted in
Inefficiency and Waste (GAO/T-RCED/AIMD-98-135, Mar. 26, 1998); and
Ecosystem Management: Additional Actions Needed to Adequately Test a
Promising Approach (GAO/RCED-94-111, Aug. 16, 1994).
INTERAGENCY COORDINATION HAS
IMPROVED
---------------------------------------------------------- Letter :3.1
Involving federal regulatory agencies, such as the Fish and Wildlife
Service, the National Marine Fisheries Service, and the Environmental
Protection Agency, at the beginning of the planning process and
maintaining their involvement throughout the process can expedite
decision-making. However, federal land management agencies have not
always sought the regulatory agencies' early involvement. For
example, before the Northwest Forest Plan was developed, a lack of
coordination among federal agencies was identified as a major cause
of the impasse that existed in the region.
In developing and implementing the Northwest Forest Plan, federal
agencies have worked together to improve coordination and
communication with positive results. For instance, according to
agency officials, the time and resources required for federal land
management agencies to consult with federal regulatory agencies as
required under the Endangered Species Act has generally declined.
However, agency officials believe additional improvements are
warranted.
The development of a plan to manage federal lands in the interior
Columbia River basin has been an interdisciplinary and interagency
effort from the beginning. While the Forest Service and BLM have led
the effort, other federal agencies have provided both staff and
funding to support the project.
OPPORTUNITIES FOR PUBLIC
PARTICIPATION HAVE IMPROVED
---------------------------------------------------------- Letter :3.2
The public has expressed its desire to become more involved in
federal land management decision-making and has demonstrated its
preference for presenting its concerns, positions, and supporting
documentation during, rather than after, an agency's development of
proposed plans. It has also signaled its intent to challenge through
administrative appeals and lawsuits decisions that it has not been
involved in reaching. The Forest Service has often not, however,
adequately involved the public throughout the decision-making
process, and efforts to address ecosystem issues and concerns have
occasionally excluded key nonfederal landowners.\11
Because the court injunctions that had enjoined the Forest Service
and BLM from selling timber until they addressed issues related to
protecting the threatened northern spotted owl and its habitat
necessitated quick action, the public was not involved in the
scientific assessment that started the development of the Northwest
Forest Plan. However, public comments were requested, and over
100,000 were received, on the draft plan. Moreover, since the plan
was approved, federal agencies have shown their willingness to
involve nonfederal parties in their decision-making. For example,
the agencies have established advisory committees that include the
general public, local governments, and other groups. Among other
things, these committees helped to determine whether agencies'
activities were in compliance with the plan's requirements.
The public has had many opportunities to participate in the
development of a plan to manage federal lands in the interior
Columbia River basin. For example, the agencies (1) held meetings
with the public in dozens of locations to identify people's concerns
about federal land management; (2) held over 200 meetings, briefings,
and consultations to keep the public and other interested parties
informed during the development of alternatives to manage federal
lands in the basin; and (3) requested, received, analyzed, and are
considering comments from nearly 83,000 parties on the seven
different land management alternatives included in the original draft
plan issued in June 1997.
--------------------
\11 See, for example, Oregon Watersheds: Many Activities Contribute
to Increased Turbidity During Large Storms (GAO/RCED-98-220, July 29,
1998).
EFFORTS ARE UNDER WAY TO
COLLECT AND USE COMPARABLE
DATA
---------------------------------------------------------- Letter :3.3
Effective interagency coordination is dependent on, among other
things, comparable environmental and socioeconomic data that are
useful and easily accessible to decisionmakers. However, data
gathered by federal agencies are often not comparable, large gaps in
the available information exist, and agencies may not know who has
what information or how existing information can be made available
within agencies, across agencies, and to the public. These data
limitations continue to hinder the development of federal land
management plans, result in legal challenges to the plans, and limit
the implementation of efforts to expedite decision-making.
Since the Northwest Forest Plan was approved, federal agencies have
made some progress in standardizing the data to be collected and in
mapping the region on a consistent scale. In addition, the Forest
Service and BLM are accumulating comparable data on, for example,
forest cover and landowners' behavior, across large areas within the
region and are testing the data to see if they are useful to field
managers for decision-making.
The scientific assessment of ecological and socioeconomic systems and
conditions in the interior Columbia River basin has contributed
greatly to data comparability. For example, maps of particular
variables, such as vegetation types, grizzly bear range, and
household income, are stored in geographic information systems that
can be retrieved not only by federal agencies but also by the public
and can be used for decision-making by many levels of government.
THE PLANS REQUIRE, OR WILL
REQUIRE, REGIONAL MONITORING
AND ADAPTIVE MANAGEMENT
---------------------------------------------------------- Letter :3.4
Once a plan is approved, agencies must move toward monitoring its
implementation to meet long-term and annual goals and objectives and
to adapting the plan's management when new information becomes
available. Historically, the Forest Service has failed to live up to
its own monitoring requirements, particularly those for monitoring
the effects of past management decisions. Not monitoring and
evaluating its decisions could expose the Forest Service to further
litigation.
The Northwest Forest Plan requires an extensive monitoring program.
The Forest Service and BLM have completed 4 years of monitoring to
determine whether the plan's requirements are being implemented, and
the agencies are beginning to evaluate whether the plan is achieving
its desired results.
A plan to manage federal lands in the interior Columbia River basin
has not been approved. However, the agencies have acknowledged the
importance of adaptive management and their original proposal
identified steps for monitoring the plan's implementation.
IN CONTRAST TO THE NORTHWEST
FOREST PLAN, THE DRAFT
MANAGEMENT PLAN FOR THE
INTERIOR COLUMBIA RIVER BASIN
HAS BEEN SUBJECT TO DELAYS AND
INCREASED COSTS
------------------------------------------------------------ Letter :4
The Northwest Forest Plan was developed and approved in about 1 year,
at a cost of about $3.5 million. By contrast, after spending over 5
years and about $41 million through the end of fiscal year 1998, the
Forest Service and BLM have exceeded time and cost estimates but have
still not made the necessary management choices and finalized a plan
to manage federal lands in the interior Columbia River basin. The
agencies estimate that they will need another $10.9 million to reach
a decision in March 2000.
Key factors that contributed to the timely and cost-effective
development of the Northwest Forest Plan included (1) the sense of
urgency created by the court injunctions, (2) the strong leadership
displayed by the administration in developing the plan, and (3) clear
objectives focusing the effort primarily on the minimum habitat needs
of the northern spotted owl and other species that depend on
old-growth forests for their habitat. Moreover, the plan provides
the agencies' land managers with adequate direction for
implementation and sets standards for holding them accountable. For
instance, federal lands in the plan area are divided into seven
categories. The lands in some categories are set aside or withdrawn
for specific uses, such as recreation, or reserved to protect habitat
for owls and other species. The lands in other categories are
available for multiple uses. The lands in each category are to be
managed in accordance with requirements that include allowable and
prohibited activities and other guidance. For example, timber
harvesting to reduce the density of trees is allowed on lands
reserved to protect owl habitat, but generally not in stands over 80
years old.
There are two major reasons why the planning effort for the interior
Columbia River basin has taken longer and cost more than anticipated.
First, the agencies underestimated how much time it would take to
address the multitude of ecological and socioeconomic issues in the
basin--a region encompassing about 8 percent of the surface area of
the United States. The ecology of the interior Columbia basin is a
diverse mixture of forest and range types that support many species,
produce a wide array of goods and services, and have varied
requirements for restoration and conservation.
The second reason for the effort's additional time and costs is that
the agencies chose to develop one or more new alternatives in
response to widespread criticism of their original draft alternatives
from the public and the Congress. A final decision on a plan to
manage federal lands in the basin is now not expected until March
2000. The fiscal year 1999 budget for the project is $5.7 million,
and the agencies estimate that they will need $5.2 million in fiscal
year 2000.
While much of the criticism reflected differences in opinion over how
the federal lands should be managed, some of it related to how
successful the agencies were in taking the steps necessary to
implement ecosystem management. One of the necessary steps is to
delineate ecosystem boundaries for consistent management. Although
the agencies did this when they selected the basin as their planning
area, they have acknowledged that their original proposal addressed
issues that are not appropriately dealt with at the scale of the
basin. These include plant and animal species with limited ranges
whose management requires site-specific information that cannot be
provided at the scale of the basin. The agencies have pledged to
focus their revision on critical broad-scale issues related to
landscape health, aquatic habitats, human needs, products and
services, and terrestrial habitats.
In announcing their intent to supplement their draft proposal with a
new alternative or alternatives that focus on basinwide issues, the
agencies made it clear that the choice of a preferred alternative or
alternatives for the interior Columbia River basin project is the
first in a series of decisions that will affect federal land
management. It is also clear that if more issues are resolved at the
basinwide scale, fewer issues will have to be resolved at smaller
scales. Conversely, if more broad-scale issues are deferred, the
agencies will later need more planning resources and time to complete
a comprehensive plan for the basin.
We believe that for the issues addressed by the draft proposal, the
agencies also failed to complete one of the essential steps in
ecosystem management--making management choices. In our past work,
we concluded that this step includes identifying (1) desired future
ecological conditions; (2) the types, levels, and mixes of activities
to meet these conditions; and (3) the distribution of activities
among land units over time.\12 Because the agencies did not complete
this step, we believe that it is difficult to determine how and where
management activities would be implemented in specific locations
under the different alternatives. Stakeholders therefore, had to
base their analyses of the alternatives on the intent of each
alternative--such as aggressively restoring degraded lands through
active management, emphasizing the production of goods and services,
or promoting restoration by establishing a system of reserves where
management activities are limited--rather than on specific expected
results.
For example, rather than allocate the estimated potential timber
harvest among administrative land units, such as national forests, as
they did for the Northwest Forest Plan, the Forest Service and BLM
allocated the estimated potential timber harvests and other
activities to noncontiguous but ecologically similar groupings of
land--called �clusters��that are scattered throughout the basin.
These clusters do not correspond to the borders of administrative
land units. (Fig. 2 shows the boundaries of forest clusters in the
basin.) Therefore, this approach did not indicate what level of
economic activity could be expected for individual national forests
or BLM management units. Hence, those economically dependent on
these units, such as timber industry employees, did not have an
adequate understanding of the economic impact of the different land
management alternatives and could not make informed choices among
them.
Figure 2: Forest Clusters in
Lands Within the Boundaries of
the Interior Columbia River
Basin Project Area
(See figure in printed
edition.)
Note: The lands in the project
area that are not shaded are
dominated by range ecosystems
rather than forests. The
agencies also divided these
areas into noncontiguous range
clusters.
(See figure in printed
edition.)
Source: Interior Columbia
Basin Ecosystem Management
Project.
(See figure in printed
edition.)
When the agencies announced that they would prepare an additional
alternative or alternatives for managing the basin and that they
would improve their proposal by focusing on basinwide issues, they
also indicated that the revision would provide only general guidance
on some of those issues. We are concerned that general guidance will
not complete the step of making management decisions and all that
that step entails. General guidance alone will not provide
stakeholders with the clear and well-defined management alternatives
they need to make informed choices, nor will it provide the Congress
and the public with the standards they need to hold federal land
managers accountable.
--------------------
\12 Ecosystem Management: Additional Actions Needed to Adequately
Test a Promising Approach (GAO/RCED-94-111, Aug. 16, 1994).
THE QUANTITY AND QUALITY OF
TIMBER FROM WESTERN FEDERAL
LANDS WILL REMAIN LOW
------------------------------------------------------------ Letter :5
The process used to develop the Northwest Forest Plan was timely and
cost-effective and successfully addressed many of the long-standing
deficiencies associated with federal land management planning.
Moreover, the broad-scale, ecosystem-based approach used to develop
the plan was sufficient for the courts to lift the injunctions
related to the spotted owl controversy. The plan has not, however,
reversed the sharp decline caused by the injunctions in the quantity
and quality of timber sold from federal lands in the Pacific
Northwest. As a result, the consequences of this decline�higher
per-unit costs for agencies to provide the timber and for loggers to
harvest it--have also not been reversed. Significant changes in this
situation are unlikely to occur under current planning and
environmental laws.
The Forest Service and BLM overestimated the volume of timber to be
harvested under their original preferred management alternative for
federal lands in the interior Columbia River basin. As a result, the
agencies created unrealistic expectations for relatively high timber
harvests that would probably not have occurred, largely because of
regulatory agencies' concerns and shortfalls in funding to implement
the plan.
THE NORTHWEST FOREST PLAN
CALLS FOR SIGNIFICANTLY
LOWER TIMBER SALES
---------------------------------------------------------- Letter :5.1
The volume of timber sold from federal lands covered by the Northwest
Forest Plan declined from a yearly average of about 5.0 billion board
feet\13 in the 1980s to a low of 297 million board feet in 1994
following the injunctions barring federal timber sales in northern
spotted owl habitat. (See app. I, fig. I.3.) After the plan was
approved, the injunctions were lifted, but timber sales were not
substantially increased. In the first 4 full fiscal years of the
plan, sales averaged about 687 million board feet per year, largely
because of restrictions imposed by the plan on how and where timber
can be commercially harvested. This level of sales is roughly
consistent with the plan's projections for the first 4 years of
implementation.
The quality of the timber sold from the plan area has also declined,
in part because of the plan's restrictions on the location and age of
trees that can be harvested. For example, the plan restricts the
harvest of older trees to protect the habitat of the northern spotted
owl and other species. Older trees are commercially valuable because
they yield relatively higher-grade timber that can be manufactured
into a broad array of wood products, including lumber. As a result
of the plan's restrictions, the proportion of this high-grade timber
harvested from national forests in the plan area has decreased from
an average of about 86 percent during the 1980s to an average of less
than 75 percent during fiscal years 1995 through 1998. (See app. I,
fig. I.4.)
As the quantity and quality of timber have declined, the per-unit
costs to the federal government and logging companies have increased
dramatically. For example, the Forest Service's per-unit costs of
operating the timber program almost doubled from $126 per thousand
board feet in fiscal year 1992 to $243 per thousand board feet in
fiscal year 1997. (See app. I, fig. I.6.) This increase is largely
attributable to the proportionally higher fixed costs, such as
expenses associated with depreciation on existing facilities and
roads, and inefficiencies inherent in smaller harvests. The agencies
have also significantly reduced the use of clear-cutting--the removal
of all trees from a timber-harvesting site at one time--as the
preferred harvesting method. The substitution of more
environmentally sensitive, but costlier harvesting methods has almost
doubled the per-unit costs to private companies of logging on federal
lands in the Pacific Northwest. (See app. I, fig. I.7.)
--------------------
\13 A board foot is a measure of wood volume equal to an unfinished
board 1 foot long, 1 foot wide, and 1 inch thick. Different methods
for estimating board feet yield different estimates. To account for
these differences, we have converted all board feet volumes into a
standard measure using the method of estimation employed by the
Forest Service's Northwest Region.
TIMBER SALES ARE UNLIKELY
TO SUBSTANTIALLY INCREASE
OVER CURRENT LEVELS
-------------------------------------------------------- Letter :5.1.1
The overall decline in the quantity and quality of timber from
federal lands covered by the Northwest Forest Plan is unlikely to be
reversed, given existing laws, including the Endangered Species Act,
and their implementing regulations and judicial interpretations.
Restrictions imposed by the plan to comply with these laws resulted
in the injunctions being lifted but also resulted in lower timber
sales relative to the 1980s. The plan initially projected that the
agencies would be able to sell an average of about 958 million board
feet per year during the plan's first decade. While this level
represents a decline of more than 80 percent from sale levels during
the 1980s, subsequent analyses of the ecological conditions of the
land by the Forest Service and BLM reduced the annual projected sale
volume to 840 million board feet for the first decade. Since then,
the Forest Service has announced that it will further reduce its
portion of the projected sale volume--thereby reducing the total for
the plan area. According to the Forest Service, the new projected
sale volume will most likely be 746 million board feet per year.
Although an annual timber sale level of 746 million board feet is
more than double the lowest level reached as a result of the federal
court injunctions, it is just a small fraction of the sale levels
experienced during the 1980s. (See app. I, fig. I.3.) Timber sales
reached their lowest level as a result of the injunctions in fiscal
year 1994, when the agencies sold about 300 million board feet, or
about 6 percent of the 5.0 billion board feet sold, on average, each
year during the 1980s. In comparison, the average annual sale level
of 746 million board feet projected by the Forest Service under the
plan equals about 15 percent of the average level sold during the
1980s. Thus, there is less than a 9-percent difference between the
predicted annual sale level under the plan and the lowest level sold
under the injunctions when compared with the average level of timber
sold during the 1980s.
Furthermore, although the agencies do not believe timber sales will
fall below the projected annual average of 746 million board feet,
they are unlikely to increase. Since the plan was approved in 1994,
18 additional species have been listed under the Endangered Species
Act as endangered or threatened in the area covered by the plan. In
addition, recent policy initiatives mean that federal lands are more
likely to assume additional responsibility for protecting threatened
and endangered species. For example, in exchange for commitments by
nonfederal land owners to protect threatened and endangered species,
the Fish and Wildlife Service and the National Marine Fisheries
Service agreed that if measures beyond those in the commitment were
needed, they would be implemented first on federal lands.
THE FOREST SERVICE AND BLM
HAVE OVERESTIMATED THE
VOLUME OF TIMBER TO BE
HARVESTED IN THE INTERIOR
COLUMBIA RIVER BASIN
---------------------------------------------------------- Letter :5.2
The volume of timber harvested from federal lands in the interior
Columbia River basin declined from a peak of 3.3 billion board feet
in fiscal year 1987 to about 900 million board feet in fiscal year
1997. According to the Forest Service and BLM, their preferred
management alternative in the original draft plan would have reversed
this trend and led to average yearly harvests of about 1.7 billion
board feet, thus providing economic support for local communities.
However, our review indicated that for this plan, as for the
Northwest Forest Plan, the agencies overestimated the volume of
timber to be harvested under the preferred management alternative.
In estimating the volume of timber to be harvested under this
alternative, the Forest Service and BLM did not adequately take into
account the concerns of federal regulatory agencies, budgetary
constraints, and the potential impact of new information and events.
For this, as for other planning efforts, the Fish and Wildlife
Service, the National Marine Fisheries Service, and the Environmental
Protection Agency expressed concern that the original preferred
alternative's emphasis on active management, including timber
harvesting, would cause unacceptable environmental consequences. In
addition, as the Forest Service did in developing some of the first
forest plans, the two agencies developed the plan's management
alternatives without reference to likely funding levels. The
agencies' preferred alternative and estimate of timber output assumed
a significant increase in appropriated funds, which the agencies are
not likely to receive. Finally, new information and events, similar
to those likely to affect timber sales in the Pacific Northwest,
could further reduce timber sales. For instance, additional species
could be listed; federal lands in the basin could assume more
responsibility for protecting wildlife and fish and their habitats;
additional federal lands could be set aside for conservation; and the
results of additional analyses could limit the acreage available for
multiple uses, including timber harvesting. For all of these
reasons, the volume of federal timber available for sale is likely to
be smaller than estimated under the agencies' preferred management
alternative.
CONCLUSIONS
------------------------------------------------------------ Letter :6
The Northwest Forest Plan is one of the first broad-scoped,
ecosystem-based plans to be developed and implemented. Experience
with it has shown that an ecological approach to planning, coupled
with urgency, strong leadership, and clear objectives, can address
many of the long-standing deficiencies associated with planning for
and managing federal lands. The plan was developed in a timely and
cost-effective manner compared to other Forest Service planning
efforts, and it contains direction to be implemented by line
managers. In addition, processes were established to, among other
things, (1) involve federal regulatory agencies and the public in
land management decision-making, (2) monitor the effects of
management decisions, (3) collect and use comparable environmental
data, and (4) adapt management to new information obtained through
monitoring and research.
However, the Northwest Forest Plan's implementation has also shown
that correcting long-standing management deficiencies will not
necessarily lead to increases in the volume or quality of timber
produced. Requirements in federal land planning and environmental
laws and their judicial interpretations have sharply reduced federal
timber sales from their average level during the 1980s and are likely
to keep them at about the current level. These requirements have
also reduced the quality of the federal timber available for sale and
have increased the costs for federal agencies to operate the timber
program and for private companies to harvest the timber.
In developing a plan to manage federal lands in the interior Columbia
River basin, the Forest Service and BLM have also worked to overcome
some long-standing planning deficiencies. However, without the sense
of urgency that focused efforts to develop the Northwest Forest Plan,
they have not demonstrated the discipline and accountability for time
and costs needed to produce a timely decision on the management of a
large and complex region. Nor have the agencies focused their plan
on those issues that should be addressed at such a large scale.
Finally, the agencies have not provided enough detail about the
possible outcomes of alternatives.
Ultimately, the Forest Service, BLM, the Congress, and other
interested parties must make some difficult decisions about managing
federal lands in the interior Columbia River basin. To do this, the
agencies will need to determine what issues are appropriately
addressed in the interior Columbia River basin plan and what issues
are appropriately addressed at smaller geographic scales. To
complete the interior Columbia River basin plan, the agencies will
then need to (1) decide what steps land managers must take to reach
clearly defined objectives that they can be held accountable for
accomplishing, (2) determine how the distribution of management
activities over time among the various federal land units, including
those activities that produce goods and services such as timber, will
be affected by basinwide management decisions, and (3) ensure that
basinwide management decisions and estimates of outputs such as
timber fully take into account environmental laws and regulations,
budgetary constraints, and other variables.
RECOMMENDATIONS TO THE
SECRETARIES OF AGRICULTURE AND
THE INTERIOR
------------------------------------------------------------ Letter :7
We recommend that the Secretaries of Agriculture and the Interior
provide additional direction to the interagency team responsible for
developing the plan for managing federal lands in the interior
Columbia River basin. Specifically, the Secretaries should direct
that in revising the draft plan to focus on those issues that are
appropriately addressed basinwide, the team should, (1) identify the
ecological and socioeconomic trade-offs among the different land
management alternatives proposed to address basinwide issues,
including the likely effects of those alternatives on ouputs such as
timber across federal land units within the basin; (2) provide land
managers with clear direction for implementation along with
performance standards for holding them accountable; and (3) make
basinwide management decisions and estimates for outputs such as
timber taking full account of existing environmental laws and
regulations, budgetary constraints, and other variables.
Given that the agencies intend the interior Columbia River basin plan
to make management decisions for a limited number of basinwide issues
and that additional management plans focused on smaller geographic
scales will therefore be needed to provide additional management
direction, we also recommend that the Secretaries direct the the
interagency team to prepare for the Congress and the public details
on how the additional plans will be integrated with the interior
Columbia River basin plan and to estimate the time and resources that
will be needed.
AGENCY COMMENTS
------------------------------------------------------------ Letter :8
We provided copies of a draft of this report to the Forest Service,
BLM, the Northwest Forest Plan's Regional Interagency Executive
Committee, and the Interior Columbia Basin Ecosystem Management
Project Executive Steering Committee for review and comment. Because
the two ecosystem management plans are interagency efforts, the
Regional Interagency Executive Committee and the Executive Steering
Committee provided comments with the concurrence of the Forest
Service and BLM.
For those sections of the report dealing with the Northwest Forest
Plan, the Regional Interagency Executive Committee generally agreed
with our findings and conclusions. However, in its comments, the
Committee emphasized a point that merits further discussion and
analysis. The Committee commented that our emphasis on the timber
program should be matched with an equal emphasis on other components
of the plan, such as interagency cooperation and the strategy
intended to restore and maintain the ecological health of watersheds.
We discussed in detail many aspects of the Northwest Forest Plan,
including its correction of long-standing management deficiencies
that we previously identified, such as a lack of interagency
cooperation. However, many of the intended benefits of the
plan--especially those associated with the long-term and overall
health of federal lands and resources--will not be realized for many
years, and accurate measures to gauge longer-term improvements have
yet to be developed. Therefore, we did not make any changes to the
report.
The Committee's comments and our responses to them are found in
appendix III of this report. The Committee also provided several
clarifications to the report, which we incorporated where
appropriate.
For those sections of the report dealing with the Interior Columbia
Basin Ecosystem Management Project, the Executive Steering Committee
generally agreed with our findings and recommendations. However, in
its comments, the Committee emphasized several points. First, the
Committee said that we did not adequately present differences in the
scope and approaches of the interior Columbia River basin project and
the Northwest Forest Plan that contributed to the relative
differences in the time and costs to develop them. We agree that
these differences are important, and we revised the draft to
highlight them. More importantly, it was not our intent to compare
the costs of the interior Columbia River basin project and of the
Northwest Forest Plan, but to compare the actual time and costs of
the project to initial estimates made by the agencies. Second, the
Committee provided us with a time line for completing the project.
As a result, we updated the report and deleted the first part of our
draft recommendation that the agencies develop a time line for
completing the project. Third, with respect to our recommendation
that the agencies identify trade-offs between management
alternatives, the Committee emphasized that there are limits to how
specific they can be about the effects of management decisions at the
basinwide scale. We acknowledge these limits and revised our
recommendation to emphasize that it applies only to those issues that
the agencies determine should be addressed at the basinwide scale.
Fourth, the Committee said that the supplemental draft environmental
impact statement would address our draft recommendation that the
agencies clearly state the impact of environmental laws, regulations,
budgetary constraints, and other variables on timber sales volumes.
However, because actions related to this recommendation are not yet
complete, we did not make any changes to it.
We added our second recommendation on the time and resources needed
to complete the planning process for federal lands in the basin after
the agencies reviewed our draft report. We believe that the
recommendation is warranted, given the limits on a basinwide decision
and the need for additional decisions at a smaller scale.
The Committee's other comments and our responses to them are found in
appendix IV of this report. The Committee also provided several
clarifications to the report, which we incorporated where
appropriate.
We conducted our work from September 1997 through March 1999 in
accordance with generally accepted government auditing standards.
Appendix V explains our methodology in detail.
We are sending copies of this report to Senator Bingaman, Ranking
Minority Member, Senate Committee on Energy and Natural Resources;
Representative George Miller, Ranking Minority Member, House
Committee on Resources; and Representative Charles Stenholm, Ranking
Minority Member, House Committee on Agriculture. We are also sending
copies of this report to the Honorable Dan Glickman, Secretary of
Agriculture; the Honorable Bruce Babbitt, Secretary of the Interior;
the Honorable Mike Dombeck, Chief of the Forest Service; the
Honorable Tom Fry, Acting Director of the Bureau of Land Management;
and other interested parties. We will make copies available to
others on request.
If you or your staff have any questions about this report, please
call me at (202) 512-3841. Major contributors to this report are
listed in appendix VI.
Barry T. Hill
Associate Director, Energy,
Resources, and Science Issues
IMPLEMENTATION OF THE NORTHWEST
FOREST PLAN ADDRESSES MANY
LONG-STANDING DEFICIENCIES BUT
CANNOT PROVIDE HISTORIC LEVELS OF
TIMBER
=========================================================== Appendix I
Experience with the Northwest Forest Plan\14 has shown that an
ecological approach to planning, coupled with a sense of urgency,
strong leadership, and clear objectives, can address many of the
long-standing deficiencies we have found associated with planning for
and managing federal lands. Compared to other Forest Service plans,
this one was developed expeditiously and cost-effectively�it took
about a year and cost about $3.5 million--and contains clear
direction to field managers. In addition, processes were established
to, among other things, (1) involve federal regulatory agencies and
the public in land management decision-making, (2) collect and use
comparable environmental data, and (3) adapt management to new
information obtained through monitoring and research.
The Northwest Forest Plan satisfied the courts so that they were
willing to lift the injunctions that had barred the Forest Service
and BLM from selling timber in northern spotted owl habitat.
However, the plan called for an 81-percent reduction in the volume of
timber sold, compared with the volume sold in the 1980s, and the
agencies have subsequently reduced this estimate. Additionally, the
quality of the timber sold relative to what was sold in the 1980s has
declined, and the agencies' costs of providing timber and loggers'
costs of harvesting it have increased significantly on a per-unit
basis.\15 Moreover, the overall decline in the volume and quality of
timber sold from federal lands in the Pacific Northwest is unlikely
to be reversed, given existing laws, including the Endangered Species
Act, and their implementing regulations and judicial interpretations.
As a result, the increases in the agencies' and loggers' per-unit
costs that were linked to this decline will also not be reversed.
--------------------
\14 We use the term �Northwest Forest Plan� to include a group of
documents that led to a formal interagency plan to manage federal
lands in the Pacific Northwest.
\15 Costs are measured in dollars per board foot. A board foot is a
measure of wood volume equal to an unfinished board 1 foot long, 1
foot wide, and 1 inch thick.
THE NORTHWEST FOREST PLAN WAS
DEVELOPED TO RESOLVE A CONFLICT
BETWEEN CONSUMPTION AND
CONSERVATION
--------------------------------------------------------- Appendix I:1
In the late 1980s and early 1990s, timber sales on lands in northern
spotted owl habitat managed by the Forest Service and BLM in the
Pacific Northwest were brought to a virtual halt by federal court
injunctions. In various rulings, the federal courts enjoined the
agencies from selling timber until they addressed issues related to
protecting the habitat of this owl,\16 which was listed as threatened
under the Endangered Species Act. In response, the President
directed his administration to develop a plan that would (1) satisfy
the courts so they would lift the injunctions, (2) protect the
environment, and (3) help stabilize the regional economy. The result
was the Northwest Forest Plan.
The Northwest Forest Plan includes two components that focus on
forest management and economic development. The first component
includes a regional land management plan that provides management
direction for the 22.3 million acres of land managed by the Forest
Service and BLM in the range of the northern spotted owl.\17 The
regional plan's development began with a scientific assessment by six
federal agencies that described current and desired ecological
conditions within the owl's range.\18 The assessment also included 10
alternatives for managing the federal lands. Each alternative
depicted a different mix of management guidance to protect habitat
for owls and other species while also providing for other uses of the
forests, including timber harvesting. The potential environmental
and economic effects of each alternative were examined and compared
in a draft supplemental environmental impact statement,\19 and a
preferred alternative was chosen by the President for further
examination in a final supplemental environmental impact
statement.\20 A record of decision,\21 signed by the Secretaries of
Agriculture and the Interior in April 1994, selected one land
management option and amended the land management plans for 19
national forests and 7 BLM districts in the Pacific Northwest\22 on
the basis of the option.
The land management plan allocated federal lands into seven
categories, including lands set aside by the agencies or withdrawn by
the Congress for specific uses, such as recreation and wilderness;
lands reserved to protect habitat for owls and other species; and
"matrix lands" (those available for multiple uses, including timber
harvesting). Lands in each category are to be managed in accordance
with requirements (standards and guidelines) established by the
record of decision. These include allowable and prohibited
activities and other guidance. For example, timber harvesting to
reduce the density of trees is allowed on lands reserved to protect
owl habitat, but generally not in stands over 80 years old. Of the
24.5 million acres of land covered by the Northwest Forest Plan, 78
percent were either set aside for specific uses, such as recreation,
or reserved to protect habitat for owls and other species. The
remaining 22 percent were available for multiple uses, including
timber harvesting.
In addition, the regional plan recognizes that a one-size-fits-all
approach may not be appropriate and allows for the requirements to be
tailored to fit the ecological conditions specific to each of 12
geographic provinces (e.g., old-growth rain forests in western
Washington and drier forests in northern California). The plan also
includes an aquatic conservation strategy intended to restore and
maintain the ecological health of watersheds and the aquatic
ecosystems within them. The strategy, among other things, requires
the Forest Service and BLM to (1) analyze conditions in watersheds
identified as key to protecting fish at risk of becoming extinct and
to providing high-quality water before beginning management
activities, such as timber harvesting, on either reserved or matrix
lands and (2) eventually conduct an analysis of conditions in all
watersheds on federal lands as a basis for ecosystem planning and
management.
The second component of the Northwest Forest Plan is an economic
assistance program aimed at helping the region adjust to changes in
federal forest management. The Environmental Protection Agency, the
Small Business Administration, and agencies within five federal
departments--Agriculture, Housing and Urban Development, Labor,
Commerce, and the Interior--are to provide $1.2 billion in funding to
communities, tribes, businesses, and individuals to help them make
the transition from dependency on federal timber to other employment
opportunities.\23 Additionally, the Corps of Engineers participated
in both the ecological and economic components of the Northwest
Forest Plan.
--------------------
\16 See, for example, Seattle Audubon Society v. Evans, 771 F.
Supp. 1081 (W.D. Wash.), aff'd, 952 F.2d 297 (9th Cir. 1991) and
Seattle Audubon Society v. Moseley, 798 F. Supp. 1484 (W.D. Wash.
1992), aff'd sub nom., Seattle Audubon Society v. Espy, 998 F.2d 699
(9th Cir. 1993).
\17 An additional 2.2 million acres of federal land within the range
of the northern spotted owl are managed primarily by the National
Park Service and are not subject to the management direction of the
Northwest Forest Plan.
\18 Forest Ecosystem Management: An Ecological, Economic, and Social
Assessment, Report of the Forest Ecosystem Management Assessment Team
(FEMAT)(July 1993). The six federal agencies were the Forest
Service, BLM, the Fish and Wildlife Service, the National Park
Service, the National Marine Fisheries Service, and the Environmental
Protection Agency.
\19 Draft Supplemental Environmental Impact Statement on Management
of Habitat for Late-Successional and Old-Growth Forest Related
Species Within the Range of the Northern Spotted Owl, Forest Service
and BLM (July 1993).
\20 Final Supplemental Environmental Impact Statement on Management
of Habitat for Late-Successional and Old-Growth Forest Related
Species Within the Range of the Northern Spotted Owl, Vols. I and
II, Forest Service and BLM (Feb. 1994).
\21 Record of Decision for Amendments to Forest Service and Bureau of
Land Management Planning Documents Within the Range of the Northern
Spotted Owl and Standards and Guidelines for Management of Habitat
for Late-Successional and Old-Growth Forest Related Species Within
the Range of the Northern Spotted Owl, Forest Service and BLM (Apr.
1994).
\22 GAO uses the term Pacific Northwest to describe lands in northern
California, western Oregon, and western Washington.
\23 The economic assistance program is not evaluated in this report.
DEVELOPMENT AND IMPLEMENTATION
OF THE NORTHWEST FOREST PLAN
HAS ADDRESSED MANY
LONG-STANDING PLANNING
DEFICIENCIES
--------------------------------------------------------- Appendix I:2
An ecosystem-based regional land management plan has helped federal
land management agencies reconcile differences in the geographic
areas that must be considered in reaching decisions under different
planning and environmental laws. Additionally, in developing and
implementing the plan, the agencies addressed long-standing
deficiencies in, and barriers to, timely, orderly, and cost-effective
land management planning. These deficiencies include a lack of (1)
accountability for the time and costs in developing plans, (2)
adequate involvement in the decision-making process by other federal
agencies and the public, (3) comparable environmental and scientific
data among agencies, and (4) monitoring to determine the effects of
past management decisions.\24
--------------------
\24 Ecosystem Management: Additional Actions Needed to Adequately
Test a Promising Approach (GAO/RCED-94-111, Aug. 16, 1994), Forest
Service Decision-Making: A Framework for Improving Performance
(GAO/RCED-97-71, Apr. 29, 1997), and Tongass National Forest: Lack
of Accountability for Time and Costs Has Delayed Forest Plan Revision
(GAO/T-RCED-97-153, Apr. 29, 1997).
DEVELOPMENT OF THE NORTHWEST
FOREST PLAN FOLLOWED THE
PRACTICAL STEPS IN
IMPLEMENTING AN ECOSYSTEM
APPROACH TO FEDERAL LAND
MANAGEMENT
------------------------------------------------------- Appendix I:2.1
Because the boundaries of administrative units and natural systems
are frequently different, 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�that exist within the boundaries of the
administrative units covered by the plans. Because the habitat of
the northern spotted owl extends over many Forest Service and BLM
administrative units, a new approach was needed. The agencies
developed the Northwest Forest Plan using an approach consistent with
the practical steps we identified to implement ecosystem
management.\25 (See fig. I.1).
The agencies accomplished the first step when they delineated an
ecosystem that matched the geographic scope of the issue at hand,
namely the habitat range of the northern spotted owl, without regard
to administrative boundaries. This allowed the agencies to analyze
ecological issues at an appropriate geographic scale, and the
resulting plan establishes a consistent boundary for management.
Other issues, such as providing high-quality water, are addressed at
smaller, more appropriate, geographic scales.
Figure I.1: Practical Steps to
Implement Ecosystem Management
(See figure in printed
edition.)
Source: Ecosystem Management:
Additional Actions Needed to
Adequately Test a Promising
Approach (GAO/RCED-94-111, Aug.
16, 1994).
(See figure in printed
edition.)
Under the second step, six federal agencies performed a scientific
assessment and also described current and desired ecological
conditions within the owl's range. The desired ecological conditions
represent the minimum level of integrity and functioning--or
threshold--needed to maintain or restore a healthy ecosystem.
Under the third step, the agencies identified in the plan the types
of activities that are prohibited in each of the seven land
categories. They also described the conditions--sometimes referred
to as desired future conditions--that should occur in each category.
To accomplish the fourth step, the plan requires a continuous
monitoring program, the results of which could lead to changes in
management direction. In addition, the plan allocated 6 percent of
the lands to 10 adaptive management areas where the agencies can
develop and test innovative land management approaches to achieve
ecological and economic goals and revise or amend the plan
accordingly. For example, one area is developing and testing
approaches to integrate timber production with the restoration and
maintenance of riparian habitat.
--------------------
\25 See, for example, Ecosystem Management: Additional Actions
Needed to Adequately Test a Promising Approach (GAO/RCED-94-111, Aug.
16, 1994) and Forest Service Decision-Making: A Framework for
Improving Performance (GAO/RCED-97-71, Apr. 29, 1997).
AFTER AN INITIAL DELAY, THE
REGIONAL PLAN WAS DEVELOPED
IN A TIMELY AND
COST-EFFECTIVE MANNER
------------------------------------------------------- Appendix I:2.2
Initially, even after federal courts enjoined the agencies from
selling timber, the Forest Service and BLM were slow to develop plans
adequate to protect the owl until the President became involved.
Fueled by a sense of urgency related to the court injunctions, as
well as strong leadership within the administration and clear
objectives, six federal agencies developed a regional land management
plan in a timely and cost-effective manner.
In October 1989, the Congress directed the Forest Service to develop
a plan to conserve the species by September 30, 1990.\26 The agency
failed to produce a plan by the deadline. In May 1991, a federal
district court judge enjoined the Forest Service from selling timber
in owl habitat, noting that the agency's failure to develop a
conservation plan exemplified a �deliberate and systematic� refusal
by the Forest Service and the Fish and Wildlife Service to comply
with the laws protecting wildlife. The court ordered that a plan be
completed by March 1992. In July 1992, the judge rejected the plan
developed by the Forest Service and issued another injunction barring
the agency from selling timber in owl habitat until it made changes
to the plan to address, among other things, the viability of other
old-growth-dependent species. The court ordered that a plan be
completed by August 1993. Similarly, in February 1992, another
federal district court judge enjoined BLM from selling timber in owl
habitat until it analyzed the effects of logging in the species'
habitat.\27
To end the impasse, the President convened a forest conference in
Portland, Oregon, in April 1993, at which he directed his cabinet to
develop the required plan. The scientific assessment by the six
federal agencies that described current and desired ecological
conditions within the owl's range was completed in about 3 months.
In April 1994, the departments of Agriculture and the Interior
approved the Northwest Forest Plan, completing their efforts a year
after the forest conference, at a cost of about $3.5 million. In
comparison, the Forest Service spent about 10 years and $13 million
revising the land management plan for the Tongass National Forest in
southeastern Alaska.\28
Key differences between the process used to develop the Northwest
Forest Plan and the process previously used by the Forest Service to
amend or revise forest plans such as the one for the Tongass National
Forest contributed to the plan's timely and cost-effective
development. These differences include (1) the sense of urgency
related to the court injunctions, (2) the strong leadership displayed
by the President and the involvement of high-ranking administration
officials in developing the plan, and (3) clear objectives based in
part on the need to preserve the habitat of the northern spotted owl
and other old-growth-dependent species.
--------------------
\26 Department of the Interior and Related Agencies Appropriations
Act for Fiscal Year 1990, P.L. 101-121, 103 Stat. 747.
\27 Portland Audubon Society v. Lujan, 784 F. Supp 786 (D. Or.
1992).
\28 Tongass National Forest: Lack of Accountability for Time and
Costs Has Delayed Forest Plan Revision (GAO/T-RCED-97-153, Apr. 29,
1997).
INTERAGENCY COORDINATION HAS
IMPROVED UNDER THE PLAN
------------------------------------------------------- Appendix I:2.3
Before the Northwest Forest Plan was developed, a lack of
coordination among federal agencies had been identified as a major
cause of the impasse that existed in the region. Virtually all
parties involved in the conflict over the use of late-successional
forests\29 agreed that federal agencies would need to work together
to improve coordination and communication.
Interagency coordination in the development of the land management
plan began with the scientific assessment by the Forest Service, BLM,
the Fish and Wildlife Service, the National Park Service, the
National Marine Fisheries Service, and the Environmental Protection
Agency. Additionally, these six agencies--together with the U.S.
Army Corps of Engineers; Agriculture's Natural Resources Conservation
Service; and Interior's Bureau of Indian Affairs, U.S. Geological
Survey, and National Biological Service\30 --developed a guide
intended to standardize the process for conducting watershed analyses
under the plan's aquatic conservation strategy.\31 The guide provides
a systematic way to understand and organize ecosystem information and
to estimate the effects of management activities. The guide has been
credited with increasing the consistency with which a watershed's
condition is assessed.
Also, in 1995, four agencies--the Forest Service, BLM, the Fish and
Wildlife Service, and the National Marine Fisheries
Service--developed a streamlined Endangered Species Act consultation
process. According to agency officials, the process has generally
decreased the time and resources needed for consultation on a project
in the area covered by the plan. However, they noted that further
improvements are still needed.
Finally, the Northwest Forest Plan created interagency committees and
an office to bring together officials from various agencies to help
establish policy and to provide scientific and research information
to line managers. For example, the Regional Ecosystem Office was
established to support a group of senior regional officials�the
Regional Interagency Executive Committee�in implementing the
Northwest Forest Plan. Members of the Regional Ecosystem Office are
detailed from each of the federal agencies responsible for forest
management in the region. The office is a focal point for
scientific, technical, administrative, and policy expertise.
According to the National Marine Fisheries Service, the Northwest
Forest Plan's interagency agreements have resulted in "substantial
staff efficiencies" and have helped to defuse "the friction that
previously resulted from conflicting agency mandates."
--------------------
\29 Late-successional forests contain trees that are at least 80
years old and can include old-growth forests made up of trees that
are at least 180 to 220 years old.
\30 In 1996, the National Biological Service became the Biological
Resources Division of the U.S. Geological Survey.
\31 Ecosystem Analysis at the Watershed Scale: Federal Guide for
Watershed Analysis, the Regional Interagency Executive Committee and
the Intergovernmental Advisory Committee, Portland, Ore. (Aug.
1995). In addition to federal agencies, tribal governments, and the
states of California, Oregon, and Washington and associated counties
helped develop the guide.
OPPORTUNITIES FOR PUBLIC
PARTICIPATION HAVE IMPROVED
UNDER THE PLAN
------------------------------------------------------- Appendix I:2.4
Virtually all parties involved in the conflict agreed that states,
tribes, local governments, and the public should have a better
opportunity to share their concerns, issues, and ideas directly with
federal decisionmakers on how the forests should be managed. Because
of the urgent need to resolve the court injunctions, the public was
not directly involved in the scientific assessment that began the
process to develop the Northwest Forest Plan. However, public
comments were requested, and over 100,000 were received, on the draft
supplemental environmental impact statement that compared the
potential environmental and economic impact of each of the 10
management alternatives included in the assessment.
Since the plan was approved, federal agencies have shown a
willingness to involve nonfederal parties in their decision-making
and to come together with these parties to discuss, understand, and
address their concerns. Toward this end, 12 Provincial Advisory
Committees were created--one for each of the geographic provinces
identified in the plan--to involve local governments, tribes, and the
public in managing the region's forests. Members of these committees
may include representatives from state, county, and tribal
governments; the timber industry; environmental groups; recreation
and tourism organizations; and the public at large, as well as
officials from the federal agencies. Among other things, these
committees participated in areawide reviews in fiscal years 1996,
1997, and 1998 to determine whether timber sales, forest roads, and
restoration activities were in compliance with the plan's
requirements (implementation monitoring).
Nonfederal parties have also been involved in analyzing watershed
conditions on Forest Service and BLM lands. For example, the
municipal watershed for the city of Sandy, Oregon, was included in a
watershed analysis conducted by the Forest Service in conjunction
with BLM, the Fish and Wildlife Service, and the city of Sandy.
After completing the watershed analysis, the Forest Service and BLM
entered into a formal memorandum of understanding with the city to
maintain or improve the quality and quantity of water from the
watershed.
EFFORTS ARE UNDER WAY TO
COLLECT AND USE COMPARABLE
ENVIRONMENTAL DATA
------------------------------------------------------- Appendix I:2.5
According to a recent Council on Environmental Quality report,\32 the
team that prepared the scientific assessment found that the agencies'
history of dealing with environmental issues on a small scale, such
as individual sites, left the agencies with data for the region that
were inconsistent from place to place and difficult to use with
precision for analyzing natural resource issues at larger scales.
Since the Northwest Forest Plan was approved, progress has been made
in standardizing the data to be collected and in mapping federal
lands on a consistent scale across the region. For example, Forest
Service and BLM data on vegetation across the region are being
combined into one map. Once the map is completed, the agencies will
be able to update the map with new information as the vegetation
changes over time. According to a BLM official, the agencies will
also use the map as a basis for other maps, such as a map of northern
spotted owl habitat.
In addition, both the Forest Service and BLM are accumulating data
across large areas within the region and testing the data to see if
they are useful to land managers for decision-making. For example,
the Forest Service is developing a data set for an area in the Coast
mountain range in Oregon that includes information on forest cover
and landowners' behavior for both federal and nonfederal lands.
Using the data set, the agency can project the effect of proposed
land management decisions over time to predict what the landscape
will look like up to 100 years in the future.
BLM has compiled a data set for the Umpqua River basin in Oregon and
may use it for long-term planning in the area. Agency officials
showed us how the data can be used to identify locations where land
management activities, such as timber harvesting, will produce the
smallest impact on the landscape. Officials from the Fish and
Wildlife Service, the National Marine Fisheries Service, and the
Environmental Protection Agency support BLM's use of the data set for
the long-term planning of projects, stating that planning based on
data across a large area will help them in reaching decisions about
the impact of BLM's projects on threatened and endangered species and
on water quality.
--------------------
\32 J. Pipkin, The Northwest Forest Plan Revisited (Sept. 1998).
Mr. Pipkin is the Director of the Office of Policy Analysis at the
Department of the Interior. The report was commissioned by the
Council on Environmental Quality.
THE NORTHWEST FOREST PLAN
REQUIRES REGIONAL MONITORING
AND ADAPTIVE MANAGEMENT
------------------------------------------------------- Appendix I:2.6
Monitoring is an essential component of natural resource management
because it provides information on the relative success of management
strategies in achieving desired ecological conditions and management
objectives. Monitoring is linked to the process of adaptive
management--a continuous cycle of planning, acting, monitoring, and
evaluating--that can lead to continuous improvement in land
management. (See fig. I.2.)
Figure I.2: Adaptive
Management Cycle
(See figure in printed
edition.)
Source: Adapted from Forest
Ecosystem Management: An
Ecological, Economic, and
Social Assessment, Report of
the Forest Ecosystem Management
Assessment Team (July 1993).
(See figure in printed
edition.)
The Northwest Forest Plan requires the agencies to monitor their land
management activities to determine whether (1) the plan's standards
and guidelines are being followed (implementation monitoring), (2)
they are achieving the plan's desired results (effectiveness
monitoring), and (3) the plan's underlying assumptions about the
activities are sound (validation monitoring). The agencies have
completed 3 years of implementation monitoring and are beginning to
do effectiveness monitoring. They have not developed a plan for
validation monitoring, but agency officials told us that some
validation monitoring is being performed.
THE NORTHWEST FOREST PLAN
PROVIDES A WIDE RANGE OF
ECOSYSTEM BENEFITS
--------------------------------------------------------- Appendix I:3
The Northwest Forest Plan was the first broad-scale attempt to apply
an ecosystem approach to resolving natural resource issues. It not
only caused the injunctions against federal timber sales to be lifted
but also provided guidance on protecting the environment across the
ecosystem, including areas critical to water quality. As a result,
the plan benefits other federal agencies�such as the National Marine
Fisheries Service, the Environmental Protection Agency, and the
National Park Service�that are not bound by the plan's standards and
guidelines.
THE NORTHWEST FOREST PLAN
PROVIDES MANAGEMENT
DIRECTION FOR MORE THAN
PROTECTING NORTHERN SPOTTED
OWL HABITAT
------------------------------------------------------- Appendix I:3.1
According to a federal judge, the agencies creating the Northwest
Forest Plan could not comply with environmental laws without planning
on an ecosystem basis. Although the original controversy focused on
protecting northern spotted owl habitat, the plan contains provisions
to protect other species and to restore and maintain watersheds
because these activities are important to the overall health of the
ecosystem.
To meet the agencies' obligations under the Endangered Species Act,
the plan designated over 10 million acres, or more than 40 percent of
the federal land in the plan area, as reserves to conserve and create
habitat for listed species. This area also provides habitat for many
other species that are not listed. The plan also requires the
agencies to gather data on the habitat and location of over 400
species in the plan area that are not listed but about which little
is known. If the agencies find rare and sensitive species among this
group, they may decide that management actions are needed to keep
them from becoming threatened or endangered.
To maintain and restore the ecological health of watersheds and the
aquatic environment, the plan established an aquatic conservation
strategy. The strategy contains four components: (1) creating
reserves to protect lands along streams; (2) designating �key�
watersheds that provide high-quality water and habitat for at-risk
fish species; (3) performing ecological analyses of key and other
watersheds to aid in planning management activities; and (4)
restoring the health of watersheds and the aquatic environment.
To implement the aquatic conservation strategy, the Northwest Forest
Plan set aside over 2.6 million acres as riparian reserves. The plan
also designated over 9 million acres as key watersheds in which no
major activity�such as timber harvesting�can take place until an
ecological analysis of the watershed has been completed. The
agencies have made progress in completing watershed analyses for both
key and other watersheds. As of 1997, the Forest Service had
completed 234 watershed analyses of the 480 it planned to complete
and BLM had completed 70 analyses, covering about 70 percent of its
lands in the plan area. Finally, the agencies have performed
watershed restoration activities. For example, from 1994 to 1997,
the Forest Service completed riparian restoration projects, such as
planting vegetation, on almost 16,000 acres.
THE NORTHWEST FOREST PLAN
PROVIDES BENEFITS TO OTHER
AGENCIES NOT DIRECTLY
AFFECTED BY THE PLAN'S
MANAGEMENT DIRECTION
------------------------------------------------------- Appendix I:3.2
Although the Northwest Forest Plan's management direction is specific
to the Forest Service's and BLM's land management activities, other
federal agencies report that they have benefited from the plan in
ways that will help them accomplish their missions. For example,
according to the National Marine Fisheries Service, it has
successfully applied the science from the plan's scientific
assessment in a variety of nonfederal habitat conservation efforts in
various parts of the country. The National Park Service pointed out
that four of its parks are adjacent to late-successional reserves
designated by the plan and that the reserves will contribute to the
parks' biological diversity, wildlife viability, and ecological
integrity. Officials from the Environmental Protection Agency have
also identified ways in which the plan has helped the agency carry
out its environmental protection missions. For example, riparian
reserve stream buffers created by the plan have enhanced source water
protection�a responsibility for the agency under the Safe Drinking
Water Act. The Environmental Protection Agency has also been able to
share watershed data gathered under the plan, thereby reducing the
burden of acquiring and managing it.
All three agencies have indicated that the interagency collaboration
that occurred during the development of the Northwest Forest Plan has
continued beyond the plan's implementation. For example, according
to the National Marine Fisheries Service, the agency has colocated a
field office with other federal agencies, resulting in improved
working relationships and enhanced resource protection. An
Environmental Protection Agency official noted that the success of
the interagency collaboration on the Northwest Forest Plan
contributed to collaboration on other efforts, such as the interior
Columbia River basin planning effort.
TIMBER VOLUME AND QUALITY HAVE
DECLINED AND COSTS HAVE
INCREASED UNDER THE NORTHWEST
FOREST PLAN
--------------------------------------------------------- Appendix I:4
The Northwest Forest Plan satisfied the courts so that they were
willing to lift the injunctions barring the Forest Service and BLM
from selling timber in northern spotted owl habitat. The plan
satisfied the requirements of the Endangered Species Act and the
National Forest Management Act and its implementing regulations. It
also provided assurance that the processes and functions of
late-successional and old-growth forest ecosystems, as well as of the
riparian habitat essential for many aquatic and terrestrial species,
would be maintained and restored. In addition, the plan provided
guidance to federal agencies on protecting the environment.
However, to comply with the statutory requirements incorporated in
the plan, the Forest Service and BLM have had to, among other things,
(1) significantly reduce the volume and commercial quality of the
timber sold and (2) significantly reduce the use of clear-cutting as
the preferred method to harvest timber.\33 As a result, the agencies'
costs to provide timber and loggers' costs to harvest it have
significantly increased on a per-unit basis.
--------------------
\33 Clear-cutting is a harvesting method that removes all trees from
a timber-harvesting site at one time.
THE VOLUME OF TIMBER SOLD
HAS DECREASED SIGNIFICANTLY
------------------------------------------------------- Appendix I:4.1
The fertile soils of the Pacific Northwest provide some of the best
conditions in the United States for growing trees, and federal lands
in the region are recognized as some of the nation's most productive
and valuable commercial forest properties. From fiscal year 1980
through fiscal year 1989--the last year before federal timber sales
in northern spotted owl habitat were barred by court-ordered
injunctions--the Forest Service and BLM sold an average of 5 billion
board feet of timber per year from the lands bounded by the plan.\34
During the first 4 full fiscal years of the plan--fiscal years
1995-98--timber sales from federal lands bound by the plan averaged
about 687 million board feet per year, or less than 14 percent of the
volume sold during the 1980s. (See fig. I.3.)
Figure I.3: Volume of Timber
Sold From Federal Lands in the
Northwest Forest Plan Area,
Fiscal Years 1980-98
(See figure in printed
edition.)
Sources: Forest Service and BLM.
The authors of the Northwest Forest Plan concluded in an
environmental impact statement that the volume of timber sold from
federal lands in the Pacific Northwest during the 1980s could not be
sustained. The plan's scientific assessment concluded that the
situation in the Pacific Northwest had reached a point where
satisfying the requirements of the Endangered Species Act and other
applicable laws required a course of action that would substantially
reduce the availability of timber from federal forests in the region
inhabited by the northern spotted owl. As a result, the Northwest
Forest Plan imposes management restrictions on late-successional
timber stands and other ecologically important areas, resulting in a
sharp decline in the projected volume of timber available for sale
from federal lands in the Pacific Northwest. The plan anticipated
that the volume of timber available for sale over the first 10 years
of the plan--called the probable sales quantity�would be about 9.58
billion board feet, or an average of about 958 million board feet per
year.\35
--------------------
\34 Different methods for estimating board feet yield different
estimates. To account for these differences, we have converted all
board feet volumes into a standard measure using the method of
estimation employed by the Forest Service's Northwest Region.
\35 This estimate does not include "other wood." Other wood is wood
that is too decayed, crooked, small, or otherwise unsuitable for
processing into a saleable product. Historically, other wood has
accounted for about 10 percent of the total harvest volume from
timber-suitable federal lands in the planning area. The original
probable sale quantity of 958 million board feet per year grew to
1.054 billion board feet (rounded to 1.1 billion board feet in some
instances) when a 10-percent increase was included for other wood.
THE QUALITY OF TIMBER
HARVESTED FROM FEDERAL LANDS
IN THE PACIFIC NORTHWEST HAS
DECLINED
------------------------------------------------------- Appendix I:4.2
Not only has the volume of timber sold from federal lands in the
Pacific Northwest declined but so also has the quality of the timber
harvested. Restrictions on the location and age of trees that can be
harvested are intended to protect and enhance the habitat of the
northern spotted owl and other species that depend on the region's
late-successional and old-growth forests. However, these
restrictions also limit the harvesting of some of the most
commercially valuable trees. For instance, restrictions on
harvesting older trees have contributed to the decline in timber
available to produce lumber and other commercially valuable
products--known as sawtimber.\36 As a proportion of timber harvested
from Forest Service lands, sawtimber fell from an average of almost
86 percent during the 1980s to an average of less than 75 percent
during fiscal years 1995-98. (See fig. I.4.)
Figure I.4: Sawtimber as a
Percentage of Total Volume of
Timber Harvested From Forest
Service Lands in the Pacific
Northwest, Fiscal Years 1980-98
(See figure in printed
edition.)
Source: Forest Service.
Moreover, the quality of the sawtimber harvested from federal lands
in the Pacific Northwest has dropped, as illustrated by the decrease
in the percentage of high-quality Douglas fir sold in the area
covered by the Northwest Forest Plan. Douglas fir accounts for about
two-thirds of the timber volume harvested from federal lands in the
Pacific Northwest. It is one of the most commercially valuable tree
species because of its size and quality. The most valuable Douglas
fir are often found in late-successional and old-growth forests.
However, the quality of the Douglas fir sawtimber that is being sold
has dropped dramatically, in part because of the Northwest Forest
Plan's restrictions on harvesting in late-successional and old-growth
areas. During the 1980s, about 22 percent of the Douglas fir
sawtimber sold from federal lands in western Oregon and western
Washington was graded as the highest quality.\37 This figure dropped
to about 9 percent for fiscal years 1995-97. (See fig. I.5.)
Figure I.5: Percentage of
High-Grade Douglas Fir Sold on
Federal Lands in Western Oregon
and Western Washington, Fiscal
Years 1980-97
(See figure in printed
edition.)
Source: Timber Data Company.
--------------------
\36 When trees are harvested and cut into logs, they are graded on
the basis of qualities such as the diameter of the log and how clear,
or free of knots, the wood is. Sawtimber is typically more valuable
than other timber because it can be manufactured into a broader array
of wood products and often contains a larger amount of clear,
high-grade wood.
\37 The highest-quality sawtimber, logs known as �peelers,� were so
named because, historically, they were "peeled" to make veneer.
Species of trees are graded on different scales. Only some species
can produce logs of sufficiently high quality to be graded as
peelers. Douglas fir grown west of the Cascade ridge is of such high
quality that it has more than one grade of peeler--it has four
grades.
TIMBER PROGRAM'S PER-UNIT
COSTS HAVE INCREASED FOR
LAND MANAGEMENT AGENCIES AND
LOGGERS IN THE PACIFIC
NORTHWEST
------------------------------------------------------- Appendix I:4.3
While the volume and quality of timber have declined, the unit cost
to the Forest Service to operate the timber program and the unit cost
to private companies that harvest the timber have risen dramatically.
In fiscal year 1992, the Forest Service spent about $126 per thousand
board feet to operate the timber program.\38 By fiscal year 1997 the
cost had almost doubled to $243 per thousand board feet.\39 (See fig.
I.6.)
Figure I.6: Cost Per Thousand
Board Feet to Operate the
Forest Service's Timber Program
in the Pacific Northwest,
Fiscal Years 1992-97
(See figure in printed
edition.)
Source: Forest Service.
The Forest Service reports that nationally, per-unit costs have
increased because the fixed costs of conducting the timber sale
program, such as the expenses associated with depreciation on
facilities and roads, have not changed, even though less timber is
being sold. Additionally, certain activities that contribute to the
cost of the timber program--such as sale preparation and harvest
administration--are less efficient at lower harvest levels. As a
result, the unit cost of performing these activities has generally
increased as the size of the timber program has decreased.
The unit cost per board foot to loggers to harvest timber on federal
lands in the Pacific Northwest has also increased dramatically, in
large part because of the more environmentally sensitive harvesting
methods required on federal lands. Virtually all of this cost
increase can be attributed to the increase in the stump-to-truck
cost, that is, the cost to fell a tree, prepare it for
transportation, and load it on a truck. (See fig. I.7.)
Figure I.7: Cost Per Thousand
Board Feet to Log in National
Forests in Western Washington
and Western Oregon, Fiscal
Years 1980-97
(See figure in printed
edition.)
Source: Timber Data Company.
These costs have increased, in part, because clear-cutting, which is
a relatively economical method of harvesting, has been significantly
reduced, and more costly and time-consuming timber-harvesting methods
are being used. For example, a growing number of federal land
managers are requiring environmentally sensitive logging techniques
that also increase costs, such as having loggers use helicopters to
remove trees from an area instead of having trucks drive to the
harvesting site, which could damage the environment.
--------------------
\38 This includes all direct and indirect costs. Direct costs
include the expenses for such activities as preparing and
administering timber sales and reforesting cutover areas. Indirect
costs mainly include the expenses for responding to appeals and
litigation, as well as general administrative costs.
\39 For fiscal year 1997, the federal government adopted new
accounting standards that require the Forest Service to include the
cost of road construction as an annual expense instead of carrying
the cost as an asset on its balance sheet. This change was
responsible for an 8.4-percent increase in the reported cost of the
Forest Service's national timber program for fiscal year 1997.
THE QUANTITY AND QUALITY OF
FEDERAL TIMBER FROM THE PACIFIC
NORTHWEST WILL REMAIN LOW AND
UNIT COSTS WILL REMAIN HIGH
--------------------------------------------------------- Appendix I:5
The overall decline in the quantity and quality of timber from
federal lands covered by the Northwest Forest Plan is unlikely to be
reversed, given existing laws, including the Endangered Species Act,
and their implementing regulations and judicial interpretations.
Although restrictions imposed by the plan to comply with these laws
caused the federal injunctions to be lifted, they also resulted in
reduced timber sales, lower-quality timber, and increases in per-unit
costs for federal agencies to operate the timber program, and for
loggers to harvest timber from federal lands. The Forest Service and
BLM estimate that the most likely volume of timber sold in an average
year during the first decade of the plan will be about 746 million
board feet. This level of annual sales is not significantly above
the lowest level of sales experienced as a result of the
injunctions�about 300 million board feet�when compared with the 5
billion board feet of timber sold in an average year during the
1980's. The restrictions imposed by the plan that reduced timber
sales to this level are likely to keep them at about this level.
Additionally, because these restrictions are also responsible for
reducing the timber's quality and increasing the program's operating
and harvesting costs, the quality and costs are unlikely to change
substantially.
TIMBER'S DECLINING QUANTITY
AND QUALITY ARE PRIMARILY
THE RESULTS OF STATUTORY
REQUIREMENTS
------------------------------------------------------- Appendix I:5.1
Although the sharp decline in the volume of timber sold can be traced
to the court injunctions and the quantity and quality of the timber
currently available for sale can be traced to specific components of
the plan, cutbacks in the timber program can generally be traced to
requirements in federal planning and environmental laws. These laws
include the Endangered Species Act, the National Forest Management
Act, the Federal Land Policy and Management Act, the Clean Water Act,
and the Clean Air Act. Further requirements are embodied in the
laws' implementing regulations and judicial interpretations.\40 These
laws define minimum levels�or thresholds�to be met to protect
individual natural resources or assign responsibility for defining
these levels to executive branch officials.\41
According to the plan, the sharp drop in timber volume from the
levels that prevailed during the 1980s is a consequence of previous
high harvest levels that severely limited the options available to
land managers attempting to comply with the environmental laws. For
example, the alternative options considered during the plan's
development that would have provided higher probable sale quantities
were not adopted because they were deemed incompatible with the
requirements of the Endangered Species Act or the National Forest
Management Act and its implementing regulations.
The decrease in the quality of federal timber sold in the Pacific
Northwest is also ultimately attributable to the requirements of
planning and environmental laws. For example, the Forest Service
believes that legal requirements--coupled with changes in public
attitudes concerning the most appropriate management priorities for
national forest lands�resulted in a shift toward using timber sales
to accomplish stewardship objectives instead of providing wood.\42
The Forest Service has shifted its management emphasis under its
broad multiple-use and sustained-yield mandate from consumption
(primarily producing timber) to conservation (primarily sustaining
wildlife and fish). It has also made clear that its overriding
mission and funding priority is to maintain and restore the health of
the lands entrusted to its care, and it has stated its intention to
limit goods and services--including commercial sawtimber and other
forest products--to the types, levels, and mixes that the lands are
capable of sustaining.\43
In the past, the primary purpose of most timber sales was to help
meet this demand for wood products; therefore, these sales included a
significant amount of commercially valuable timber. However, more
and more timber sales are being designed to help attain various
stewardship objectives. For example, sales are being used as a tool
to accelerate the development of late-successional conditions in
young forest stands. While these sales are designed to yield a
profit whenever circumstances allow, the size, type, and quality of
the timber sold are dictated by the desired stewardship outcome. As
a result, the types of trees being harvested have shifted from live
to dead and dying trees and from large-diameter to small-diameter
trees.
This shift in emphasis is notable in the Pacific Northwest. Between
fiscal year 1992 and fiscal year 1997, the proportion of timber
harvested from Forest Service lands in the Pacific Northwest
primarily to help meet the nation's demand for wood fell from about
96 percent to about 39 percent of the harvest's total volume, while
the proportion of timber harvested for forest stewardship purposes
grew from less than 1 percent to about 55 percent.\44 (See fig.
I.8.)
Figure I.8: Timber Volumes
Harvested From Forest Service
Lands in the Pacific Northwest
to Meet Commodity and
Stewardship Objectives, Fiscal
Years 1992-98
(See figure in printed
edition.)
Source: Forest Service.
--------------------
\40 Forest Service Decision-Making: A Framework for Improving
Performance (GAO/RCED-97-71, Apr. 29, 1997).
\41 Ecosystem Management: Additional Actions Needed to Adequately
Test a Promising Approach (GAO/RCED-94-111, Aug. 16, 1994).
\42 See for example, Forest Management Program Report, Fiscal Year
1997, Forest Service (FS-627, July 1998) and Changing Economics of
the National Forest Timber Sale Program, Forest Service (1998).
\43 Forest Service: Lack of Financial and Performance Accountability
Has Resulted in Inefficiency and Waste (GAO/T-RCED/AIMD-98-135, Mar.
26, 1998) and Forest Service Management: Little Has Changed as a
Result of the Fiscal Year 1995 Budget Reforms (GAO/RCED-99-2, Dec.
2, 1998).
\44 A third type of timber harvest, personal use sales, remained
relatively steady, ranging between about 4 and about 7 percent of the
Forest Service's volume in the Pacific Northwest between fiscal year
1992 and fiscal year 1997. Personal use harvests are intended
primarily to supply firewood, Christmas trees, and other
miscellaneous forest products to individuals for their own
consumption.
THE QUANTITY AND QUALITY OF
TIMBER SOLD ARE UNLIKELY TO
INCREASE SUBSTANTIALLY OVER
LEVELS EXPERIENCED DURING
THE INJUNCTIONS
------------------------------------------------------- Appendix I:5.2
According to the original estimate in the Northwest Forest Plan, the
likely amount of timber the Forest Service and BLM would be able to
sell during the first decade of the plan�the probable sale
quantity�would average about 958 million board feet per year.
However, by August 1995, just 16 months after the plan was finalized,
the Forest Service and BLM had reduced the probable sale quantity to
840 million board feet per year. Moreover, the Forest Service
expects to further reduce its portion of the probable sale quantity
and estimates that the resulting total probable sale quantity will
fall to an average annual level of 746 million board feet�22 percent
less than the originally estimated probable sale quantity. The drop
in probable sale quantity bears out the plan's observation that
changes could occur. For example, the plan noted that timber sale
levels could be affected by requirements for conducting additional
environmental analysis or setting aside additional lands to protect
threatened or endangered species or by a change in the acreage
allocated to riparian reserves following an analysis and inventory of
intermittent steams. Officials told us that the probable sale
quantity will likely change yet again.
Even if the probable sale quantity does not drop below an average of
746 million board feet per year, this level of sales is only a small
fraction of the levels common during the 1980s, and, from this
perspective, it is not significantly higher than the levels under the
federal court injunctions (see fig. I.3). Timber sales reached
their lowest level as a result of the injunctions in fiscal year
1994, when the agencies sold 297 million board feet, or about 6
percent of the 5 billion board feet sold, on average, each year
during the 1980s. The most likely average annual sale level under
the plan is about 746 million board feet, or about 15 percent of the
level sold during the 1980s. There is only a 9-percent difference
between the level predicted under the plan and the lowest level under
the injunctions when compared with the average level during the
1980s.
Furthermore, even if the probable sale quantity does rise, it is
unlikely that timber sales will increase significantly. Since the
plan was approved, additional species have been listed as threatened
and endangered, and agreements have been signed that require federal
lands to assume a growing proportion of the responsibility for
protecting wildlife and fish. These developments suggest that timber
sales under the Northwest Forest Plan may have peaked in fiscal year
1996, when 841 million board feet were sold.
While the management direction in the Northwest Forest Plan is
intended to support the recovery of the northern spotted owl and
conserve other species dependent on old-growth forests by maintaining
the ecological health of forested and aquatic ecosystems, 18 species
in the plan area have been listed as endangered or threatened under
the Endangered Species Act since the plan was approved--15 fish, 1
frog, and 2 plants. Although 9 of these species were recently listed
(March 1999), the new listings are not expected to affect federal
timber sales in the Pacific Northwest because the listings are for
salmon and trout species whose habitat requirements are similar to
those of the salmon and trout species already listed. The additional
listings, however, further reduce the chance that restrictions in the
plan protecting these species' habitat will be lifted.
In addition, the pressure to maintain habitat on federal lands to
protect threatened and endangered species is expected to grow. The
Forest Service and BLM are required by the National Environmental
Policy Act to consider activities occurring on nonfederal lands in
deciding which activities may occur on their lands. We believe this
requirement, coupled with recent policy initiatives, means that
federal lands will assume a growing proportion of the responsibility
for protecting threatened and endangered species and that these
species' habitats will increasingly be concentrated on Forest Service
and BLM lands in the Pacific Northwest and elsewhere.
Additionally, the National Marine Fisheries Service and the Fish and
Wildlife Service have incorporated a �no surprises� policy into
habitat conservation plans under section 10 of the Endangered Species
Act.\45 Under this policy, nonfederal landowners, in exchange for
adopting a habitat conservation plan to protect threatened and
endangered species, will be exempt from land-use restrictions and
other mitigation measures affecting covered species beyond those
restrictions and measures already addressed in the habitat
conservation plan. If the status of the species unexpectedly worsens
because of circumstances not addressed in the habitat conservation
plan, the burden of imposing additional conservation measures would
fall primarily on the federal government and on nonfederal landowners
that have not developed a habitat conservation plan. There are about
3 million acres of nonfederal land under habitat conservation plans
within the range of the northern spotted owl.
Finally, according to a recent report on the Northwest Forest
Plan,\46 part of the administration's intent in developing a regional
land management plan was to minimize the impact of protecting and
recovering threatened and endangered species on nonfederal lands.
Seventy-eight percent of the lands were either set aside for specific
uses, such as recreation, or reserved to provide habitat for
endangered and threatened species and other species dependent on
late-successional forest for habitat. Timber harvesting on these
lands is either prohibited or allowed only for stewardship purposes.
Timber harvests for commercial purposes are allowed on the remaining
22 percent of the lands but are subject to management provisions.
While these provisions are intended to preserve late-successional
forests for habitat, they also have the effect of limiting timber
harvests. If more late-successional acreage is preserved on federal
lands, less must be preserved on nonfederal lands to provide
sufficient habitat for endangered, threatened, and other species that
depend on this type of forest for habitat. Essentially, the plan
established a trade-off, increasing habitat protection requirements
and timber-harvesting restrictions on federal lands in order to
increase the nonfederal acreage available for timber harvesting and
other nonconservation uses.
--------------------
\45 63 Fed. Reg. 8859 (Feb. 23, 1998).
\46 J. Pipkin, The Northwest Forest Plan Revisited (Sept. 1998).
DEFICIENCIES IN DEVELOPING A
MANAGEMENT PLAN FOR THE INTERIOR
COLUMBIA RIVER BASIN HAVE RESULTED
IN DELAYS AND UNFULFILLED PROMISES
========================================================== Appendix II
The development of a plan to manage about 72 million acres of federal
land in the interior Columbia River basin is at a critical juncture.
From the outset, the Forest Service and BLM have stated that a
regional ecosystem management approach will cut the cost of amending
federal land management plans in half because decisions will be made
once for the region rather than for each federal land unit in the
basin. However, after spending over 5 years and almost $41 million
through fiscal year 1998, the agencies have still not made the
necessary management choices and selected a management plan for the
basin. The Forest Service and BLM estimate that they will need at
least another $10.9 million to reach a decision in March 2000. One
view expressed by both the public and some in the Congress is that
funding for the effort should be terminated. According to some
holding this view, the ecological and socioeconomic data that have
been gathered and the analyses that have been performed should be
forwarded to local Forest Service and BLM administrative units for
the agencies to consider and use in revising their land management
plans.
In developing a management plan for the interior Columbia River
basin, the Forest Service and BLM have attempted to address
ecological issues along the boundaries of natural systems rather than
along the boundaries of administrative units and have worked to
overcome some long-standing planning deficiencies. They have (1)
worked in collaboration with other federal agencies, (2) offered many
opportunities for public participation in the process, and (3)
conducted a scientific assessment that has generated greatly improved
ecological and socioeconomic data on the basin. However, developing
the plan has taken far longer and cost far more than expected.
Some of the delays and higher costs occurred because the agencies
significantly underestimated the time and effort required to address
a multitude of ecological and socioeconomic issues and human
activities at such a large geographic scale. Additional time and
funds are being expended because the agencies decided to develop one
or more new management alternatives in response to widespread
criticism of their original draft alternatives from the public and
the Congress. We believe that this criticism can be attributed, in
part, to the failure of the agencies to limit their proposal to those
issues that are appropriately addressed at the scale of the basin and
to include for those issues the elements necessary for a successful
ecosystem management plan. The agencies asked for comments on a
draft management plan that spelled out the basic intent of seven
different alternative strategies but that did not provide adequate
detail to determine how the strategies would be implemented or what
effects they would have in particular locations. As a result, the
Congress and other interested parties could not make informed choices
among the alternatives. Moreover, as they did for the Northwest
Forest Plan, the Forest Service and BLM overestimated the volume of
federal timber to be harvested under their preferred land management
alternative.
A MULTISTEP PROCESS IS BEING
USED TO DEVELOP A MANAGEMENT
PLAN FOR THE INTERIOR COLUMBIA
RIVER BASIN
-------------------------------------------------------- Appendix II:1
The plan to manage federal lands in the interior Columbia River basin
is being developed to avoid a conflict between consumption and
conservation such as the one in the Pacific Northwest that led to
injunctions against timber sales on federal lands. Table II.1
summarizes the major events in developing the plan.
Table II.1
Time Line of Major Events in Developing
a Management Plan for the Interior
Columbia River Basin
--------- -------- --------------------------------------------------------------------
1993 July The President directs the Forest Service to develop a scientifically
sound ecosystem-based strategy for national forests in Oregon and
Washington east of the crest of the Cascade mountain range.
1994 January The Forest Service and BLM sign a charter expanding the scope of the
strategy to include BLM lands in eastern Oregon and Washington.
July The Forest Service and BLM expand the scope of the effort to include
the upper Columbia River basin in Idaho, Montana, Wyoming, Utah, and
Nevada.
1996 June The agencies issue a framework for ecosystem management in the
project area.
December The agencies issue an integrated scientific assessment of the
project area.
1997 May The agencies issue a scientific evaluation of the potential effects
of preliminary management alternatives.
June The agencies issue a more detailed scientific assessment of the
project area.
June The agencies release for public comment a draft environmental impact
statement for each of the two planning areas: eastern Oregon and
Washington and the upper Columbia River basin, which together make
up the interior Columbia basin. The comment period is to end October
6, 1997.
Septembe The agencies extend the public comment period to February 6, 1998.
r
December The agencies extend the public comment period to April 6, 1998.
1998 March In response to a congressional mandate, the agencies issue an
analysis of the economic and social conditions of communities in the
project area.
March The public comment period is extended to May 6, 1998, to allow time
to review the March 1998 analysis of economic and social conditions.
May 6 The public comment period ends. Nearly 83,000 comments were
received.
October The agencies issue an analysis of public comments on the draft
environmental impact statements.
October The Secretaries of Agriculture and the Interior announce their
8 decision to present one or more new alternatives in a supplemental
draft environmental impact statement sometime in mid-1999.
1999 Septembe A supplemental draft environmental impact statement is to be
r released for public comment.
2000 March A final environmental impact statement and record of decision are to
be issued.
-----------------------------------------------------------------------------------------
In March 1993, environmental groups petitioned the Forest Service's
Pacific Northwest (Region 6) office to revise its minimum management
requirements for old-growth-dependent wildlife species on national
forests in Oregon and Washington east of the crest of the Cascade
mountain range (the Eastside planning area). The petitioners claimed
that the requirements in effect at the time, which were intended to
ensure the continued viability of certain old-growth-dependent
species, (1) lacked credibility and (2) had not been developed for
other old-growth-dependent species that needed them. The petitioners
also contended that the region had no alternative for the Eastside
area but to adopt the type of large-scale planning done under court
order in the range of the northern spotted owl. They requested a
moratorium on timber harvesting and road building in the Eastside
area's mature and old-growth forests.
In July 1993, the President directed the Forest Service to develop a
scientifically sound ecosystem-based management strategy for the
Eastside area's national forests. He also directed that the strategy
be based on a forest health study that had been completed in May 1993
by a team of agency scientists, as well as other studies.
In January 1994, the Forest Service and BLM signed an "Eastside
Ecosystem Management Project" charter that expanded the scope of the
strategy to include all lands managed by BLM in eastern Oregon and
Washington. The charter called for four products: (1) a framework
for ecosystem management, (2) a scientific assessment of the interior
Columbia River basin, (3) an environmental impact statement that
presented a preferred alternative for managing Forest Service and BLM
lands in eastern Oregon and Washington, and (4) a scientific
evaluation of the management alternatives in the environmental impact
statement. According to the agencies, the preferred alternative in
the environmental impact statement should both restore degraded
habitats and provide commodities to help support local communities.
In July 1994, the Forest Service and BLM expanded the scope of the
planning effort to include the development of a strategy for managing
federal lands in much of Idaho, western Montana, and small portions
of Nevada, Wyoming, and Utah (the Upper Columbia River Basin planning
area). The effort to develop management strategies for both the
Eastside planning area and the upper Columbia River basin planning
area is known as the Interior Columbia Basin Ecosystem Management
Project.
Between May 1994 and July 1995, the Forest Service issued three
interim management strategies. One established riparian, ecosystem,
and wildlife standards for timber sales in eastern Oregon and
Washington (the Eastside Screens).\47 Another established
requirements for managing anadromous fish\48 in eastern Oregon and
Washington, Idaho, and portions of California.\49 The third
established requirements for managing inland native fish.\50 The
ecosystem management framework called for in the January 1994 charter
was completed in June 1996.\51 It described the principles and the
planning and analysis processes for managing ecosystems in the basin
at multiple geographic scales and resolutions of data.
An integrated scientific assessment of the interior Columbia River
basin was issued in December 1996.\52 A scientific evaluation of the
seven land management alternatives contained in a February 1996
internal working draft of the environmental impact statement was
completed in May 1997.\53
In June 1997, the agencies released a more detailed version of the
scientific assessment.\54 That same month, the Forest Service and BLM
also issued two draft environmental impact statements for public
comment (dated May 1997)�one for the Eastside planning area and
another for the Upper Columbia River Basin planning area.
The draft environmental impact statements are very similar to each
other. Both addressed the environmental, economic, and social
effects of seven different land management alternatives representing
a wide range of management prescriptions. These alternatives
included a preferred alternative to aggressively restore forest,
rangeland, and watershed health through active management as well as
alternatives to maintain the status quo, emphasize the production of
goods and services, establish a system of reserves on federal lands
within which management activities would be limited, and others.
The original closing date for public comments on the draft
environmental impact statements was October 6, 1997. However, in
September 1997, the comment period was extended to February 6, 1998,
to give the public more time to review the voluminous documents. In
total, the detailed scientific assessment, draft environmental impact
statements, and associated documents ran to nearly 6,000 pages. In
December 1997, the comment period was extended to April 6, 1998.
Then, in March 1998, it was extended to May 6, 1998, to give the
public time to review a report issued that month on the economic and
social characteristics of the basin and the estimated effects of the
seven different land management alternatives in the environmental
impact statements on communities in the basin.\55 The report was
prepared pursuant to the Department of the Interior and Related
Agencies Appropriations Act of 1998 (P.L. 105-83).
In an October 8, 1998, letter to key members of the Congress, the
Secretaries of Agriculture and the Interior announced that, because
of widespread criticism of the June 1997 draft environmental impact
statements by both the public and the Congress, the Forest Service
and BLM would issue one or more new management alternatives in a
supplemental draft environmental impact statement in mid-1999.
According to the Secretaries' letter, the supplemental draft
environmental impact statement would be followed by another public
comment period. Agency officials have since told us that the
supplemental draft environmental impact statement is to be released
for public comment in September 1999 and a final environmental impact
statement and record of decision are to be issued in March 2000.
--------------------
\47 Interim Management Direction Establishing Riparian, Ecosystem,
and Wildlife Standards for Timber Sales, Forest Service (May 20,
1994; amended on June 5, 1995, and July 31, 1995).
\48 Anadromous fish (e.g., salmon and steelhead) hatch in freshwater,
migrate to the ocean, mature there, and return to freshwater to
reproduce.
\49 Implementation of Interim Strategies for Managing Anadromous
Fish-producing Watersheds in Eastern Oregon and Washington, Idaho,
and Portions of California, Forest Service (Feb. 24, 1995). This
strategy is known as PACFISH.
\50 Inland Native Fish Strategy, Forest Service (July 28, 1995).
This strategy is known as INFISH.
\51 Richard W. Haynes, Russell T. Graham, and Thomas M. Quigley,
tech. eds., A Framework for Ecosystem Management in the Interior
Columbia Basin and Portions of the Klamath and Great Basins, Forest
Service, Pacific Northwest Research Station, General Technical Report
PNW-GTR-374 (Portland, Ore.: 1996).
\52 Thomas M. Quigley, Richard W. Haynes, and Russell T. Graham,
tech. eds., Integrated Scientific Assessment for Ecosystem
Management in the Interior Columbia Basin and Portions of the Klamath
and Great Basins, Forest Service, Pacific Northwest Research Station,
General Technical Report PNW-GTR-382 (Portland, Ore.: 1996).
\53 Thomas M. Quigley, Kristine M. Lee, and Sylvia J. Arbelbide,
tech. eds., Evaluation of EIS Alternatives by the Science
Integration Team, Forest Service, Pacific Northwest Research Station,
General Technical Report PNW-GTR-406 (Portland, Ore.: 1997).
\54 Thomas M. Quigley, and Sylvia J. Arbelbide, tech. eds., An
Assessment of Ecosystem Components in the Interior Columbia Basin and
Portions of the Klamath and Great Basins (vols. I-IV), Forest
Service, Pacific Northwest Research Station, General Technical Report
PNW-GTR-405 (Portland, Ore.: 1997).
\55 Nicholas E. Reyna, Richard H. Phillips, and Gerald W.
Williams, Economic and Social Conditions of Communities: Economic
and Social Characteristics of Interior Columbia Basin Communities and
an Estimation of Effects on Communities from the Alternatives of the
Eastside and Upper Columbia River Basin Draft Environmental Impact
Statements, Interior Columbia Basin Ecosystem Management Project
(1998).
DEVELOPMENT OF THE PLAN HAS
ADDRESSED SOME LONG-STANDING
DECISION-MAKING DEFICIENCIES
AND ACCOMPLISHED SOME OF THE
STEPS NECESSARY FOR ECOSYSTEM
MANAGEMENT
-------------------------------------------------------- Appendix II:2
In developing a management plan for the interior Columbia River
basin, the Forest Service and BLM have attempted to address
ecological issues along the boundaries of natural systems and have
worked to overcome some of the long-standing deficiencies that have
plagued federal land management decision-making. The agencies have
(1) collaborated with other federal agencies, (2) involved the public
in the decision-making process, and (3) conducted a scientific
assessment to develop improved ecological and socioeconomic data on
the basin. At the same time, the agencies have also taken some of
the steps that we believe are necessary to implement ecosystem
management.
FEDERAL AGENCIES HAVE
COORDINATED THE PLANNING
EFFORT FROM THE BEGINNING
------------------------------------------------------ Appendix II:2.1
The Forest Service and BLM are the lead agencies on the Interior
Columbia Basin Ecosystem Management Project; however, the project has
been a multiagency effort from the beginning. An executive steering
committee has directed the project. The committee is composed of
three Forest Service regional foresters, three BLM state directors,
two Forest Service research experimental station directors, a deputy
regional director of the Environmental Protection Agency, and
regional directors of the National Marine Fisheries Service and the
Fish and Wildlife Service.
The committee created an ad hoc interagency senior-level team of
senior executives from the Forest Service, BLM, and three federal
regulatory agencies�the Environmental Protection Agency, the Fish and
Wildlife Service, and the National Marine Fisheries Service. This
team's purpose was to ensure that the draft environmental impact
statements complied at the basin scale with the requirements of the
many relevant land management and environmental protection laws,
including the National Forest Management Act, the Federal Land
Management and Policy Act, the National Environmental Policy Act, the
Endangered Species Act, the Clean Water Act, and the Clean Air Act.
The draft environmental impact statements also called for the Forest
Service and BLM to develop a memorandum of understanding with the
three regulatory agencies that would facilitate collaboration in
implementing the project.
Two separate groups have carried out the overall planning effort.
One group--known as the Science Integration Team--was responsible for
developing three of the four products called for in the January 1994
charter--the framework for ecosystem management, the scientific
assessment of the interior Columbia River basin, and the scientific
evaluation of the management alternatives in the draft environmental
impact statements. The other group--known as the Environmental
Impact Statement Team--is responsible for developing the two
environmental impact statements. Both groups are interdisciplinary
and interagency teams of biologists, botanists, geologists,
economists, sociologists, and others. They have consisted primarily
of Forest Service and BLM staff but have also included
representatives from the Environmental Protection Agency; Interior's
U.S. Geological Survey, National Biological Service,\56 Fish and
Wildlife Service, and Bureau of Mines; Commerce's National Oceanic
and Atmospheric Administration and National Marine Fisheries Service;
and universities. Other cooperating agencies include the National
Park Service, the Bureau of Reclamation, and the Bonneville Power
Administration.
The vast majority of the project's costs have been borne by the
Forest Service and BLM, but other agencies have also contributed
staff and resources. The Forest Service spent about 85 percent and
BLM about 15 percent of the nearly $41 million spent by those two
agencies on the project as of the end of fiscal year 1998. In
addition, the Environmental Protection Agency estimates that it spent
$487,600 on the project between fiscal year 1994 and January 1998,
primarily for salaries. The Fish and Wildlife Service estimates that
it has spent about $250,000 per year on developing the plan since
fiscal year 1995.
--------------------
\56 In 1996, the National Biological Service became the Biological
Resources Division of the U.S. Geological Survey.
THE PUBLIC HAS PARTICIPATED
SINCE THE PLANNING EFFORT
BEGAN
------------------------------------------------------ Appendix II:2.2
The public has had many opportunities to participate in the planning
process. Before developing the draft environmental impact
statements, the Environmental Impact Statement Team held scoping
meetings in dozens of locations with members of the public to
identify issues and concerns associated with the lands managed by the
Forest Service and BLM. While developing the draft environmental
impact statements, the team held over 200 informational meetings,
briefings, and consultations. Nearly 83,000 citizens; advocacy
groups; corporations; and federal, tribal, state, and local agencies
commented on one or both of the draft environmental impact
statements. An independent team of natural resource professionals
from the Forest Service and BLM prepared a content analysis of those
comments,\57 and the Environmental Impact Statement Team will
consider them in preparing the supplemental draft environmental
impact statement.
According to the content analysis of the public comments on the draft
environmental impact statements, �many are frustrated with the
process for public collaboration and suspect their input is not being
considered by government decision-makers.� However, as we have
observed in reviewing other federal land management planning efforts,
while the benefits of working together cooperatively often outweigh
the costs of early and continuous public involvement, dissatisfaction
with the agencies' process for public involvement often cannot be
dissociated from dissatisfaction with the outcome of the process.
Thus, some parties opposed to the preferred management alternative in
the draft environmental impact statements--which would aggressively
restore forest, rangeland, and watershed health through active
management but not emphasize the production of goods and
services--may be expressing dissatisfaction with the agencies'
process for public involvement. These parties may also be expected
to avail themselves of statutory or regulatory opportunities for
administrative appeal and judicial review if they are similarly
dissatisfied with the management alternative or alternatives
scheduled to be presented in the supplemental draft environmental
impact statement.
--------------------
\57 Final Analysis of Public Comment for the Eastside and Upper
Columbia River Basin Draft Environmental Impact Statements, Content
Analysis Enterprise Team (1998).
EFFORTS ARE UNDER WAY TO
COLLECT AND USE COMPARABLE
DATA
------------------------------------------------------ Appendix II:2.3
The scientific assessment of ecological and socioeconomic systems and
conditions in the basin greatly contributed to data comparability for
the basin. The Science Integration Team assembled over 170 �data
layers,� or maps, of particular variables, such as vegetation types,
grizzly bear range, employment, and income. These data are stored in
geographic information systems and can be retrieved not only by
federal land managers at the forest or district level but also by the
public. As a result, pertinent information--which is not restricted
to the agencies' administrative boundaries or jurisdictions--can be
used for decision-making by many levels of government. Despite these
benefits, many of the comments on the draft environmental impact
statements criticized the uses of data from the scientific
assessment.
DEVELOPMENT OF A MANAGEMENT
PLAN FOR THE INTERIOR
COLUMBIA RIVER BASIN
FOLLOWED THE FIRST PRACTICAL
STEPS IN IMPLEMENTING AN
ECOSYSTEM APPROACH TO
FEDERAL LAND MANAGEMENT
------------------------------------------------------ Appendix II:2.4
In addition to addressing several long-standing planning
deficiencies, the Forest Service and BLM are using an approach in the
interior Columbia River basin that is consistent with the first two
practical steps needed to implement ecosystem management (see fig.
I.1). They have (1) delineated ecosystems at several geographic
scales based on watersheds and (2) conducted a scientific assessment
to better understand the ecosystems' ecologies. The agencies are now
in the process of completing the third step--making management
choices. They have also acknowledged the importance of the fourth
step--adaptive management--and have proposed monitoring steps to
determine whether the plan's management direction is being followed
(implementation monitoring) and whether the plan is accomplishing the
desired conditions (effectiveness monitoring).
In the past, when the Forest Service and BLM developed a separate
land management plan for each of their administrative units, they
produced 74 separate land management plans for the basin. In
developing a basinwide plan, the agencies recognized that
decision-making at the level of an administrative unit resulted in a
fragmented and, perhaps, inconsistent approach to addressing many of
the broader-scale ecological issues that transcend the boundaries of
national forests and BLM districts. Therefore, as is consistent with
the first practical step of ecosystem management, they are using
watersheds at three different geographic scales as the plan's
building blocks. The broadest scale is essentially the basin itself,
which encompasses about 144 million acres and contains about 75
million acres of federal land managed by the Forest Service or
BLM.\58 The basin was then divided into 164 subbasins averaging
800,000 to 1,000,000 acres in size, over 2,000 watersheds averaging
50,000 to 100,000 acres, and over 7,000 subwatersheds averaging
15,000 to 20,000 acres.
Under the second practical step of ecosystem management, the
scientific assessment--completed at a cost of about $22.7
million--has provided extensive knowledge of the interior Columbia
River basin. The initial integrated assessment examined past and
present biophysical (i.e., aquatic, terrestrial, and landscape),
social, and economic systems on all lands in the basin regardless of
ownership and discussed the probable outcomes of the agencies'
current management practices and trends. An expanded version of the
assessment provided more detail on terrestrial, aquatic, landscape,
economic, and social conditions in the basin.
--------------------
\58 The draft management plans address 72 million of the 75 million
acres.
DELAYS AND INCREASED COSTS CAN
BE TRACED PRIMARILY TO THE
MAGNITUDE OF THE EFFORT AND THE
FAILURE TO PRESENT AN ADEQUATE
DRAFT PLAN
-------------------------------------------------------- Appendix II:3
The delays and increased costs that have been and will be incurred to
develop a plan to manage federal lands in the interior Columbia River
basin can be traced primarily to two factors. First, the Forest
Service and BLM significantly underestimated the time and effort
required to address the multitude of ecological and socioeconomic
issues and human activities that they considered for an area
encompassing roughly 8 percent of the United States. Second, the
management plan that the agencies proposed in June 1997 was widely
criticized, and, as a result, they are spending additional time and
money developing a new approach for the basin that will yield one or
more new management alternatives.
Some criticism of the original proposal focused on the agencies'
decision to address issues that were not basinwide in nature. We
also believe that although the agencies presented alternatives in
June 1997 that reflected different management strategies, they did
not clearly identify how the alternatives would be implemented or
what their consequences would be in particular locations. These are
elements that we believe are necessary for a successful ecosystem
management plan. Without this information, the Congress and other
interested parties could not make informed choices among the proposed
management alternatives. Moreover, without this specificity, the
chosen management alternative would have been difficult, if not
impossible, for federal land managers to implement, monitor,
evaluate, and be held accountable for.
THE SIZE AND SCOPE OF THE
PROJECT LED TO UNANTICIPATED
DELAYS AND COSTS
------------------------------------------------------ Appendix II:3.1
The broad geographic scope of the planning area, coupled with the
multitude of issues and activities that the agencies decided to
address, presented the agencies with a daunting challenge in
developing a plan to manage federal lands in the interior Columbia
River basin. Reviewing the draft proposal also posed a challenge to
the public that the agencies acknowledged by extending the original
120-day comment period to 330 days. As is clear, the Forest Service
and BLM underestimated the overall time and effort that would be
required to develop a plan.
The scope of the effort has included a multitude of ecological and
socioeconomic issues affecting both forests and rangelands. For
example, the scientific assessment and draft plan have addressed not
just old-growth-dependent species, but other endangered and
threatened species--such as anadromous fish (including salmon) and
the grizzly bear--with different and/or more extensive habitat
requirements. They have also addressed issues such as costly
outbreaks of wildfires, insects, and diseases; invasions of exotic
weeds; declines in soil fertility and water and air quality;
wilderness preservation; mounting legal challenges; and unpredictable
flows of commodities such as timber and livestock forage.
As the issues increase, so too do the number of human activities that
need to be addressed in developing a management plan to restore the
health of forests and rangelands in the basin. The scope of the
assessment included not only timber harvesting and road building, but
also fire suppression; livestock grazing; mining; damming and water
diversions; agricultural, industrial, urban, and residential
development; and the deliberate or accidental introduction of
nonnative plants, insects, and diseases.
Because the basin is so large and so many issues are being addressed,
the process is taking much longer and costing much more than
anticipated. For instance, in 1994, when the Forest Service and BLM
added the Upper Columbia River Basin planning area, they doubled the
geographic scope of the planning effort. (See fig. 1.) The charter
called for the draft environmental impact statement for the Eastside
planning area to be completed by January 1995. In April 1995, after
the agencies decided to do an environmental impact statement for the
upper Columbia River basin planning area, the Chief of the Forest
Service announced that the draft statements would be issued in the
fall of 1995. The date for issuing the draft statements was later
postponed to August 1996, and the statements were finally released in
June 1997. The public comment period for the draft statements was
originally 120 days, but the agencies ultimately extended it to 330
days to give people time to review the volumes of scientific data and
wide-ranging management alternatives.
The budget for the project has also grown since it started. The
initial estimated cost for the assessment and the Eastside management
plan was $5 million. In 1995, the agencies stated that the 3-year
budget (through fiscal year 1996) for the expanded project area was
$31 million. As of the end of fiscal year 1998, the Forest Service
and BLM had spent nearly $41 million.
CRITICISM OF THE DRAFT PLAN
LED TO A DECISION TO PREPARE
A SUPPLEMENTAL DRAFT
ENVIRONMENTAL IMPACT
STATEMENT
------------------------------------------------------ Appendix II:3.2
Faced with widespread criticism over the agencies' preferred
alternative in the draft plan, the Secretaries of Agriculture and the
Interior wrote to Members of Congress in October 1998 that they would
�pursue alternative proposals to meet the interests and concerns of
the public� and present them in a supplemental draft environmental
impact statement. This effort will add time and costs to the
project. The agencies now expect to issue the supplemental statement
in September 1999 and anticipate that a final plan will be approved
in March 2000. The fiscal year 1999 budget for the project is $5.7
million (some of which would have been needed even without the
decision to prepare new alternatives). According to the project
team, another $5.2 million will be needed in fiscal year 2000 to
complete the plan.
Criticism of the original proposal was, indeed, widespread, coming
from environmental organizations and conservationists, resource-based
industries, local and tribal governments, and federal agencies. The
nature of the criticism was also broad. The public critiqued, among
other things, (1) the feasibility of trying to develop a management
plan at the scale of the basin for the issues that the agencies
addressed; (2) the clarity and specificity of the proposed management
direction; (3) the range of the proposed alternatives; (4) the
quantity, quality, and interpretation of scientific data; (5) the
depth of coverage of specific issues; and (6) the projected outcomes
of the preferred alternative.
While much of the criticism could have been anticipated, given the
controversial nature of the issues, the first two categories of
criticism relate to how the agencies handled the first and third
steps of ecosystem management. As shown in fig. I.1, the first step
toward ecosystem management is to delineate the boundaries of
ecosystems at several geographic scales across which consistent
management can be applied. As part of that step, we believe that it
is also necessary to identify the issues that are appropriately
addressed at those scales. In their original draft proposal, the
agencies did delineate ecosystems at different scales and attempted
to address both basinwide and subbasin issues. In their October 8,
1998, letter to key Members of Congress, the Secretaries of
Agriculture and the Interior stated that the new management
alternative(s) in the supplemental draft environmental impact
statement and record of decision would focus on the limited number of
issues that must be resolved at the basin level. Issues that are
subbasin in scale will be addressed through other planning efforts.
The letter stated that the new Interior Columbia Basin Ecosystem
Management Project's approach would include basinwide direction built
around four basic components: aquatic habitat; terrestrial species
habitat; landscape health; and human needs, products, and services.
According to the letter, the aquatic and terrestrial approach will
attempt to protect wide-ranging species, such as anadromous fish,
lynx, and wolverine, by ensuring that adequate habitat is available
across administrative units. The aquatic strategy will also address
basinwide considerations that arise from the agencies'
responsibilities under the Clean Water Act. The needs of plants and
animals with smaller ranges will be addressed at the most appropriate
geographic scale. By reducing the number of issues covered by the
proposal, the agencies may either address or make moot some of the
public criticism. For example, criticism of how the original version
addressed a particular sensitive species that has a small range would
not be relevant under a new approach that does not attempt to address
that species' needs.
As of February 1999, the planning effort's Environmental Impact
Statement Team was sorting out the issues that should be addressed in
the basinwide supplemental draft environmental impact statement from
those that should be addressed later at the subbasin and watershed
scales. According to these officials, issues that are not basinwide
but that extend beyond the boundaries of national forests or BLM
units will be addressed by adjacent units working together. They had
not decided how the agencies would oversee the plan's implementation
to determine whether the basinwide management direction was being
followed and whether it was accomplishing the desired conditions.
Some of the public comments, as well as our observations, suggest
that the agencies did not complete the third step of ecosystem
management for certain issues. The third step is to make management
choices that identify (1) the desired future ecological conditions;
(2) the type, level, and mix of activities needed to meet those
conditions; and (3) the distribution of activities among land units
over time. While the June 1997 proposal articulated the broad
strategic differences among the proposed management alternatives, it
did not provide detailed information on the desired future
conditions, activities, and distribution of activities for each one.
Without such detailed information for each of the alternatives,
stakeholders cannot readily associate particular ecological outcomes
and economic outputs with each one, and analyses of the alternatives
must be based on their intent, rather than on specific expected
results.
For example, the draft environmental impact statements included
�desired ranges of future conditions� that could be expected in 50 to
100 years if the management direction specified in an alternative
were implemented. The draft environmental impact statements
specified management direction through objectives and standards.
Objectives are indicators used to measure progress toward achieving a
desired future condition and are designed to be accomplished in 10
years. Standards are requirements to act or refrain from acting in a
way intended to achieve the objectives. Collectively, the objectives
and standards should identify the activities that are required,
allowed, or restricted on federal lands in the basin.
According to one description in the draft environmental impact
statements of a desired range of future economic conditions,
"Economic activity is generated in rural communities, including
private sector employment, government agency employment, income,
number of recreation visits, and revenues shared with local
governments.� An indicator to measure progress toward achieving these
conditions states that the agencies' objective is to "derive social
and economic benefits, promote commercial activity, and foster demand
for labor and capital formation through producing a mix of goods and
services." Most, if not all, of the seven land management
alternatives in the draft environmental impact statements would have
met these desired economic conditions and this objective. However,
the level of economic activity generated in rural communities under
each of the alternatives could have varied significantly.
The level of economic activity generated in rural communities under
each of the alternatives in the draft environmental impact statements
could also have varied significantly with the activities that would
have been required, allowed, or restricted on particular national
forests or BLM districts. For instance, the Northwest Forest Plan
allocated the estimated level of potential timber sales over the
first 10 years of the plan among the national forests and BLM
districts covered by the plan. Thus, individuals, companies, and
communities economically dependent on these lands had an expectation
about the future availability of timber from them, and federal land
managers could plan and be held accountable for meeting these
targets. Conversely, the draft environmental impact statements for
the interior Columbia River basin allocated estimated potential
timber sales and other activities to noncontiguous, but ecologically
similar, �clusters� of forests and rangelands scattered throughout
the basin. (See fig. II.I for the boundaries of forest clusters.)
The draft environmental impact statements did not, however, identify
where in each cluster an activity would likely occur. Without
knowing the estimated levels of potential timber sales and other
activities on national forests or BLM districts, those economically
dependent on the forests or districts did not have an adequate
understanding of how much economic activity might be generated at the
local level by federal timber sales and other activities.
Figure II.1: Forest Clusters
in Lands Within the Boundaries
of the Interior Columbia River
Basin Project Area
(See figure in printed
edition.)
Note: The lands in the project
area that are not shaded are
dominated by range ecosystems
rather than forests. The
agencies also divided these
areas into noncontiguous range
clusters.
(See figure in printed
edition.)
Source: Interior Columbia
Basin Ecosystem Management
Project.
(See figure in printed
edition.)
According to the analysis of public comments, many were critical of
the how complete the agencies were in making management decisions
about ecological issues as well. Many commented that the objectives
and standards for management activities were inconsistent, were too
vague to be quantified or measured, or lacked time frames and
locations. For example, one professional society wrote that many
contradictory goals and directions exist and that it was not clear
who would decide which way to go when trade-offs are necessary. The
Fish and Wildlife Service wrote that the restoration direction in the
preferred alternative was not clearly developed into a strategy that
included guidelines, time frames, and measurable objectives. The
Service went on to say that much more information was needed on the
actions for carrying out the restoration, how it would be
implemented, and how progress and compliance would be measured.
Another theme of the comments was that watershed management
activities must be more clearly defined so that the public can
understand what activities will result from a decision. According to
the summary, most comments on specific wildlife habitat issues noted
that the public and wildlife would benefit from clearer, more
precise, and more accurate descriptions of the proposed management.
With respect to management for viable populations of wildlife, many
commented that there was little difference among the objectives,
standards, and guidelines for the different alternatives, making it
difficult to determine whether the standards and guidelines could
achieve the intended differences.
The agencies announced their intent to limit the focus of the revised
alternatives to issues that are basinwide in scale. However, the
Secretaries' letter to Members of Congress also indicated that the
revised alternatives would contain only general guidance on some of
those issues. For example, the letter said that landscape health
issues, such as the rapid spread of noxious weeds and the potential
for costly and dangerous fires, would be addressed though general
objectives and guidance and that the specific design for
on-the-ground activities would be appropriately addressed at the
subbasin or local level. We are concerned that general guidance will
not be adequate to provide the necessary standards of accountability
for land managers, the Congress, or the public. Furthermore, it is
possible that general guidance on basinwide issues will not provide
these stakeholders with the clear and well-defined management
alternatives they expect. For example, project managers told us in
January 1999 that they had not decided whether the supplemental
environmental impact statement would contain an estimate of commodity
levels under the new alternatives. This was reiterated in the
comments on our draft report made by the Interior Columbia Basin
Ecosystem Management Project's Executive Steering Committee when it
wrote that specific prescriptions related to such things as timber
harvest and grazing levels would not be appropriate at the scale of
the basin.
The public is accustomed to Forest Service and BLM land management
plans that provide a high level of detail on land allocations,
project activities, and commodity outputs. The directors of the
interior Columbia River basin project have told us that it is not
possible to provide for the entire basin the level of detail that one
might expect for a national forest. What is possible, they say, is
to make basinwide decisions about management strategies and then make
more refined decisions at a smaller scale.
Indications from the October 8, 1998, letter, however, are that the
revised proposal will provide less rather than more detail on
management steps and outcomes. If so, to limit criticism such as
they received on the original proposal, the agencies must make it
clear that the purpose of the project is to decide on a broad
strategy for management in the basin�whether that strategy be active
management, letting nature take its course (passive management), or
emphasizing commodity production�and that they cannot produce a plan
for this scale that is as detailed as a plan for a single
administrative unit.
If the purpose of the revised proposal is to present broad
alternative strategies, two other observations are relevant. First,
the Chief of the Forest Service has often stated over the last 2
years that the agency's primary goal is to maintain or restore the
health of the land and that active management is necessary to achieve
this goal. A decision that would not do much more than adopt active
management as the strategy for the interior Columbia River basin,
therefore, would not represent a significant advancement. Second, if
fewer decisions are made at a basinwide level, more decisions must be
made at a subbasin level. As the balance shifts toward local
decision-making, the amount of time and money required to complete
individual unit management plans, as well as to complete the overall
planning process for lands in the basin, will increase.
THE QUANTITY AND QUALITY OF
FEDERAL TIMBER IN THE INTERIOR
COLUMBIA RIVER BASIN WILL
CONTINUE TO DECLINE
-------------------------------------------------------- Appendix II:4
Besides not providing the specific information decisionmakers needed
to make informed choices among the seven different land management
alternatives, the draft environmental impact statements overestimated
the volume of federal timber to be harvested under the preferred land
management alternative. As a result, the Forest Service and BLM
created unrealistic expectations, and the Congress and other
interested parties were asked to make choices on the basis of
incorrect information about the alternative's ability to generate
economic activity within the basin.
THE VOLUME OF TIMBER
HARVESTED HAS DECREASED
SIGNIFICANTLY
------------------------------------------------------ Appendix II:4.1
The volume of timber harvested from federal lands in the interior
Columbia River basin has declined steeply since fiscal year 1990
following years of high output. Timber harvests on federal lands in
the basin reached historically high levels in the late 1980s. The
Forest Service and BLM harvested an average of just over 3 billion
board feet from fiscal year 1985 through fiscal year 1990. Timber
harvests on these lands declined steeply starting in fiscal year
1991, averaging just over 1.5 billion board feet from fiscal year
1991 through fiscal year 1997, with the lowest volumes occurring in
the most recent years. (See fig. II.2.) This decline can be
attributed to the three interim strategies (PACFISH, INFISH, and the
Eastside Screens), requirements in planning and environmental laws,
and changes in public values and the agencies' mission and funding
priorities.
Figure II.2: Volume of Timber
Harvested From Forest Service
and BLM Units Entirely Within
the Interior Columbia River
Basin, Fiscal Years 1985-97
(See figure in printed
edition.)
Source: Interior Columbia Basin Ecosystem Management Project.
THE QUALITY OF TIMBER
HARVESTED ON FEDERAL LANDS
IN THE BASIN WILL DECLINE
------------------------------------------------------ Appendix II:4.2
In the draft environmental impact statements, the Forest Service and
BLM cautioned that trees would have been harvested under their
preferred management alternative primarily to restore the health of
forest ecosystems rather than to produce wood fiber. As a result,
the trees would have been small in diameter and would have had less
commercial value.
For example, timber stands would have been selected for harvesting or
thinning to reduce the dense growth that makes small trees
susceptible to insects, diseases, or catastrophic wildfires.\59 Or,
timber would have been harvested from the ecologically undesirable
even-age tree stands often planted after clear-cutting. In addition,
the preferred alternative would have required that a specified number
of large trees be left standing.
--------------------
\59 See Thomas M. Quigley, Kristine M. Lee, and Sylvia J.
Arbelbide, tech. eds., Evaluation of EIS Alternatives by the Science
Integration Team, Vol. 1, Forest Service, Pacific Northwest Research
Station, General Technical Report PNW-GTR-406 (Portland, Ore.: 1997)
and Western National Forests: Catastrophic Wildfires Threaten
Resources and Communities (GAO/T-RCED-98-273, Sept. 28, 1998).
THE FOREST SERVICE AND BLM
OVERESTIMATED THE VOLUME OF
FEDERAL TIMBER TO BE
HARVESTED UNDER THEIR
PREFERRED ALTERNATIVE
------------------------------------------------------ Appendix II:4.3
According to the Forest Service and BLM, the preferred management
alternative in the draft environmental impact statements�which, they
said, would have aggressively restored forest, rangeland, and
watershed health through active management--would have reversed the
trend of declining timber harvests on federal lands in the basin.
Data on recent timber harvests that we obtained from the agencies,
which were not included in the draft environmental impact statements,
showed that, according to the Forest Service and BLM, the volume of
timber that would have been harvested from federal lands in the basin
under the preferred alternative would have exceeded by 81 percent the
volume harvested in fiscal years 1996 and 1997 under the three
interim management strategies. However, our review indicates that
the agencies overestimated the volume of federal timber to be sold
under their preferred management alternative, just as they did under
the Northwest Forest Plan.
Under their preferred alternative, the Forest Service and BLM
estimated that an average of about 1.7 billion board feet per year
would have been harvested over the first 10 years of plan. Other
alternatives, including the one that emphasized the production of
goods and services, would have yielded even higher volumes of timber.
However, federal regulatory agencies have expressed concern, as they
have for other planning efforts, that the preferred alternative's
emphasis on active management would have caused unacceptable
environmental consequences.\60 In addition, as the Forest Service did
in developing some of the first forest plans,\61 the Forest Service
and BLM developed the management alternatives without reference to
likely funding levels.\62 The agencies' preferred alternative and
their estimate of timber output were predicated on a significant
increase in appropriated funds, which they are not likely to receive.
The regulatory agencies' concerns and fiscal constraints would have
reduced the volume of federal timber to be harvested under the
preferred management alternative.
Projections of the volume of timber to be harvested from federal
lands in the basin may also be reduced in response to new information
and events. Legislative requirements to consider new information and
events, such as the listing of a new species under the Endangered
Species Act, have made it difficult for the Forest Service and BLM to
predict when any decision can be considered final and can be
implemented, reducing the agencies' ability to achieve the objectives
in their plans.\63
--------------------
\60 See, for example, Tongass National Forest: Lack of
Accountability for Time and Costs Has Delayed Forest Plan Revision
(GAO/T-RCED-97-153, Apr. 29, 1997) and Forest Service
Decision-Making: A Framework for Improving Performance
(GAO/RCED-97-71, Apr. 29, 1997).
\61 Forest Service: Issues Related to Managing National Forests for
Multiple Uses (GAO/T-RCED-96-111, Mar. 26, 1996).
\62 In their October 8, 1998, letter to Members of Congress, the
Secretaries of Agriculture and the Interior said they had asked the
regional executives to develop a plan that can accommodate a range of
funding levels for Congress and the administration to consider.
\63 Forest Service Decision-Making: A Framework for Improving
Performance (GAO/RCED-97-71, Apr. 29, 1997).
FEDERAL REGULATORY
AGENCIES WERE CRITICAL OF
THE PREFERRED ALTERNATIVE
---------------------------------------------------- Appendix II:4.3.1
Although the Forest Service and BLM are responsible for managing
their lands to sustain multiple uses, including timber production,
federal regulatory agencies are responsible for implementing and
enforcing environmental laws and regulations on those lands. Because
of their disparate missions and responsibilities, federal regulatory
agencies sometimes disagree with federal land management agencies on
an acceptable level of risk to individual natural resources and on
the best approaches for achieving environmental objectives.
Failure to reach agreement with the federal regulatory agencies
almost certainly ensures that a plan will not be implemented. In
particular, the Fish and Wildlife Service and the National Marine
Fisheries Service will formally consult with the Forest Service and
BLM under section 7 of the Endangered Species Act before any decision
is reached on a basinwide plan. If the regulatory agencies find that
the proposed management alternative does not meet the requirements of
the Endangered Species Act, they will issue a jeopardy opinion--an
opinion that asserts that the alternative would appreciably reduce
the likelihood of a listed species' survival and recovery. The
issuance of a jeopardy opinion would effectively prevent the plan
from being implemented as proposed.
In commenting on the draft environmental impact statements, three
federal regulatory agencies�the National Marine Fisheries Service,
the Fish and Wildlife Service, and the Environmental Protection
Agency�expressed concern that the management alternative preferred by
the Forest Service and BLM would not adequately protect species'
habitat, water quality, or other natural resources and would
therefore not meet the minimum requirements set by such laws as the
Clean Water Act and the Endangered Species Act. The planning
effort's interdisciplinary and interagency Science Integration Team,
although not possessing the authority of the regulatory agencies,
raised similar concerns about the preferred alternative.
The three federal regulatory agencies and the Science Integration
Team criticized the assertion by the Forest Service and BLM that
active management could continue at current or higher levels. They
were concerned that the high level of activity being proposed, even
if done in the name of ecological restoration, would have
unacceptable consequences on species' habitat and water quality.
For instance, the Science Integration Team wrote, in discussing the
need for active versus passive restoration, that "there are instances
where long-term benefits [of active restoration] may not exceed
short-term environmental costs or adverse ecosystem impacts, making a
passive restoration approach more appropriate." One consequence of
less emphasis on active management and more emphasis on passive
management would be less timber sold. (Other consequences, according
to the agencies, would be fewer activities such as prescribed burning
and noxious weed treatment.)
The National Marine Fisheries Service expressed concern that efforts
to restore lands above valley floors and streams (upland areas),
which would include timber harvesting, would further degrade already
degraded aquatic ecosystems and would likely cause further extinction
of aquatic species. The Environmental Protection Agency expressed
concern that �aggressive restoration� under the agencies' preferred
alternative would likely cause road construction and logging in
otherwise roadless areas that provide habitat for many different
species. The agency commented that such restoration could pose �a
significant risk to aquatic and terrestrial resources--both in the
short and long term." The Fish and Wildlife Service commented that
the alternatives did not �adequately address recovery of listed
species, nor preclude the need for future listings in context with
land management."
The regulatory agencies proposed specific changes to the preferred
management alternative that would have restricted commodity
production. For example, the Fish and Wildlife Service recommended
that a particular standard be modified to protect additional
large-diameter Douglas fir trees. The National Marine Fisheries
Service recommended that the preferred alternative be amended to
restrict timber harvesting in a larger portion of riparian areas and
old-growth forests. The agency also commented that the preferred
alternative attempted to meet only the minimum requirements for
listed and sensitive species and that managing to these �lower
limits� was not acceptable. Reducing the acreage available for
timber harvesting and reducing the risk to listed and sensitive
species would result in less timber being sold.
BUDGETARY CONSTRAINTS
WILL LIMIT THE VOLUME OF
TIMBER TO BE SOLD OR
HARVESTED
---------------------------------------------------- Appendix II:4.3.2
Because the trees to be harvested under the preferred management
alternative often would have had low or no commercial value, the
revenue generated from them would not have covered the costs of their
removal. For instance, while pointing out that small-diameter trees
have become much more prevalent in today's forests, the Science
Integration Team observed that the trees would be difficult for the
agencies to sell, particularly if the alternative required expensive
logging methods, such as removing trees with helicopters rather than
trucks, to reduce the impact of logging on the lands. The project
team estimated that the agencies would need significant additional
appropriations to implement the preferred alternative's active
restoration approach.
The Forest Service and BLM estimated in 1997 that fully funding the
preferred alternative's implementation would cost approximately $268
million per year. Funding at this level would require federal land
management and regulatory agencies to obtain an increase in current
funding levels of about $137 million, or about twice their current
levels for the sort of work described in the draft environmental
impact statements.
We believe that the costs of aggressively restoring forest,
rangeland, and watershed health through active management, as the
Forest Service and BLM originally proposed, would be likely to
require even more appropriated funds than the agencies estimated.
For example, agency officials and outside analysts agree that one
restoration activity�harvesting small-diameter trees to reduce the
risk of catastrophic wildfire--may require hundreds of millions of
dollars a year in appropriated funds.\64 Our preliminary analysis of
the Forest Service's fuel reduction costs indicates that about $725
million a year may be needed through fiscal year 2015 to treat the 39
million acres in the interior West at high risk of uncontrollable
wildfire. The interior Columbia River basin falls completely within
the interior West and contains a significant portion of the 39
million acres at high risk.
At a May 15, 1997, congressional hearing, the Chairman of the
Subcommittee on Interior and Related Agencies, Senate Committee on
Appropriations, informed the Forest Service and BLM that it would be
virtually impossible to come up with the money needed to implement
the preferred management alternative. Other members of the Senate
Committee on Appropriations also expressed reservations about the
future availability of appropriated funds to implement the agencies'
preferred alternative.
The Fish and Wildlife Service and the Environmental Protection Agency
have also raised doubts about the availability of funds. In
commenting on the draft environmental impact statements, the Fish and
Wildlife Service recommended "that continued effort to define and
implement a selected alternative be based on reasonably predictable
human and fiscal resources." The Environmental Protection Agency
commented that "given the large increase in projected restoration
activities, there is some question as to whether full implementation
is possible under current funding levels, as assumed in the [draft
environmental impact statements]."
The draft environmental impact statements did not assess the impact
of lower funding levels on environmental restoration, commodity
production, or local economic activity. However, the Forest Service
and BLM estimated that about 45 percent of their costs to implement
the preferred alternative would have been for timber harvesting.
Therefore, less than full funding would probably have reduced the
volume of timber sold or harvested.
--------------------
\64 Western National Forests: A Cohesive Strategy Is Needed to
Address Catastrophic Wildfire Threats (GAO/RCED-99-65, Apr. 2,
1999).
NEW INFORMATION AND
EVENTS MAY REDUCE THE
VOLUME OF TIMBER SOLD
---------------------------------------------------- Appendix II:4.3.3
As has occurred in the Pacific Northwest, the volume of timber to be
sold from federal lands in the basin may also be reduced in response
to new information and events. Additional species could be listed as
endangered or threatened, or habitat deemed critical to listed
species' protection could be designated, under the Endangered Species
Act. Additional agreements with nonfederal landowners could be
signed that would require federal lands to assume more responsibility
for protecting wildlife and fish. Additional analyses and
assessments at the subbasin and watershed levels could reduce the
acreage available for multiple uses. Finally, additional lands could
be set aside for conservation�as wilderness, wild and scenic rivers,
national monuments, and recreational areas. Any one of these events
could reduce the agencies' ability to achieve the commodity
objectives in their plan.
(See figure in printed edition.)Appendix III
COMMENTS FROM THE NORTHWEST FOREST
PLAN'S REGIONAL INTERAGENCY
EXECUTIVE COMMITTEE
========================================================== Appendix II
(See figure in printed edition.)
The following are GAO's comments on the Regional Interagency
Executive Committee's letter dated April 5, 1999.
GAO COMMENTS
1. We agree that there are many components to the plan besides the
timber program and many ways to measure the benefits of the Northwest
Forest Plan besides commodity production. Components of the
Northwest Forest Plan, such as interagency coordination and
monitoring, are discussed in detail in the report. The aquatic
conservation strategy and the potential contribution of the plan to
the overall health of the ecosystem are also discussed in the report.
However, we could not provide more detail because many of the plan's
contributions, especially to the overall health of the ecosystem and
its sustainability, will not be fully realized for many years.
Additionally, as we noted in March 1998 testimony,\65 the Forest
Service has not developed objective, verifiable accomplishment
measures and criteria that focus on actual improvements and gauge
longer-term (5- to 10-year) trends in the condition of specific
resources or attributes of environmental quality. Therefore, it is
not yet possible to accurately measure the plan's contributions to
improved ecosystem sustainability, healthier forests, and cleaner
water. Finally, our review of the Northwest Forest Plan was limited
to the regional plan developed to provide management direction for
22.3 million acres of federal lands in the Pacific Northwest and did
not include the plan's other major component�an economic adjustment
(worker and community assistance) initiative.
2. In our report, we compare federal timber sale levels for three
important periods: (1) the 10-year period (fiscal years 1980-89)
prior to the federal court injunctions that brought timber sales to a
virtual halt, (2) the level of timber sales under the injunctions
(fiscal years 1990-94), and (3) the projected level of timber sales
during the first decade after the injunctions were lifted (fiscal
years 1995-2004). Additionally, the graphs in this report provide
timber sale and other data by year for fiscal years 1980-98.
3. We recognize that technological improvements have allowed some
mills in the Pacific Northwest to make better use of smaller-diameter
trees. However, as stated in our report, the quality, and thus the
commercial value, of trees harvested from federal lands in the
Pacific Northwest has declined.
(See figure in printed edition.)Appendix IV
--------------------
\65 Forest Service: Lack of Financial and Performance Accountability
Has Resulted in Inefficiency and Waste (GAO/T-RCED-98-135, Mar. 26,
1998).
COMMENTS FROM THE INTERIOR
COLUMBIA BASIN ECOSYSTEM
MANAGEMENT PROJECT'S EXECUTIVE
STEERING COMMITTEE
========================================================== Appendix II
(See figure in printed edition.)
The following are GAO's comments on the Interior Columbia Basin
Ecosystem Management Project's Executive Steering Committee's letter
dated April 6, 1999.
1. We agree that there are important differences in the size and
complexity of the areas addressed by the Interior Columbia Basin
Ecosystem Management Project and the Northwest Forest Plan that have
contributed to the differences in the amount of time and money spent
on each. We did not intend to suggest that the two plans should have
been completed over a similar period of time at a comparable cost.
Rather, our point with respect to the interior Columbia River basin
plan was that it has taken significantly longer and cost much more
than the agencies anticipated. We revised the body of our report to
emphasize some of the differences between the two plans, noting that
the interior Columbia River basin plan covers a larger geographical
area and its development included more opportunities for public
participation.
2. We consider the Committees' commitment to issuing a supplemental
draft environmental impact statement for public comment in September
1999 and to completing the project by March 2000 to be fully
responsive to the recommendation in our draft report that the
interagency team be directed to establish a time line for revising
the draft plan. We therefore updated the time line in the report to
reflect these dates (see table II.1) and deleted this recommendation.
3. It is apparent from the Committee's comments and from the
Secretaries' October 8, 1998, letter to Members of Congress that the
interior Columbia River basin plan will not provide a comprehensive
blueprint for managing the federal lands in the basin. According to
the Committee, the supplemental draft environmental impact statement
will include the best estimate that science can provide of the
effects of their proposed actions and will give land managers enough
direction to make site-specific project decisions in the context of
broad-scale information. Later in their comments, the Committee
wrote that the land management agencies' plans have traditionally
provided specific prescriptions for such things as timber harvests
and grazing levels but that this type of prescription would be
inappropriate for a plan at the scale of the basin.
In a draft of this report, we recommended that the project identify
the ecological and socioeconomic trade-offs among the different land
management alternatives and provide land managers with clear
direction and performance standards for implementation. We
acknowledge that the environmental impact statement and final plan
for the interior Columbia River basin cannot be as specific with
respect to trade-offs or performance standards as the plans for
managing national forests or BLM lands. We therefore revised the
recommendation to refer only to those issues that the agencies
determine need to be addressed at a basinwide scale. Nevertheless,
we continue to believe that, for those basinwide issues, the agencies
must thoroughly describe the ecological and socioeconomic trade-offs
of the different management approaches so that the Congress, the
public, and other interested parties can meaningfully evaluate the
different alternatives.
Because a basinwide impact statement or record of decision will not
be able to describe in detail all management activities throughout
the basin, additional management decisions will have to be made at a
scale smaller than the basin. We are reminded of early estimates by
the agencies that a basinwide scientific assessment and decision
would cut their planning costs in half. Therefore, we also revised
the recommendation to stress that it is important for the agencies to
tell the public and the Congress how this decision-making process
will unfold, how much it will cost, and how long it will take.
4. The Committee commented that it has received clear direction from
the Secretaries of Agriculture and the Interior to recognize budget
realities and the requirements of environmental laws in completing
the project. However, because the supplemental statement and
subsequent planning documents have not yet been issued and the team's
actions are not complete, we made no changes to our recommendation.
5. To avoid the implication that the agencies withdrew any of their
original management alternatives, we revised the report to say that
they are developing one or more new alternatives.
In addition to the agency letter printed in this appendix, the
Committee's comments included an attachment with several technical
observations on, for example, the estimated budget for the project in
fiscal year 2000. We have revised the report to respond to these
comments, where appropriate.
The attachment also included another substantive issue. The
Committee said our report should not evaluate the effectiveness of
the strategy solely on the basis of its impact on timber production.
They emphasized the importance of the plan for other variables,
including the habitats of wildlife such as salmon, bulltrout, grizzly
bear, lynx, and 187 other species of concern. We agree that the
interior Columbia River basin plan reviewed in this report should
ultimately be evaluated on the basis of much more than its impact on
timber production. However, the plan is still in the proposal phase
and its ecological benefits have yet to be achieved. While our
discussion of the interior Columbia River basin plan's potential
impact on timber production is also speculative, one of our three
objectives was to report on the actual or expected effect of the plan
on the quantity and quality of timber sold from federal lands.
OBJECTIVES, SCOPE, AND METHODOLOGY
=========================================================== Appendix V
Concerned about the potential costs, time, and effectiveness of
broad-scoped, ecosystem-based analyses and studies, the Chairmen of
the Senate Committee on Energy and Natural Resources, the House
Committee on Resources, and the House Committee on Agriculture asked
us to examine the Northwest Forest Plan and the Interior Columbia
Basin Ecosystem Management Project.
In this report, we used as criteria the practical steps in
implementing an ecosystem approach to federal land management and
identified deficiencies and barriers within the federal land
management agencies' decision-making processes to discuss (1) the
extent to which each effort has addressed long-standing planning
deficiencies, (2) the problems encountered by the agencies that have
contributed to delays and increased costs, and (3) the effect that
the plans have had, or are expected to have, on the quantity and
quality of timber sold from federal lands covered by the plans.
Our review of the Northwest Forest Plan was limited to the regional
plan developed to provide management direction for 22.3 million acres
of land managed by the Forest Service and BLM in the Pacific
Northwest. We did not review the plan's other major component--an
economic adjustment initiative to assist workers, tribes, and
communities affected by reductions in federal timber harvests. In
addition, in performing our work, we did not evaluate any scientific
documents or conclusions used or being used in either the Northwest
Forest Plan or the Interior Columbia Basin Ecosystem Management
Project.
For our review of the Northwest Forest Plan, we met with, and
examined documents provided by, managers and staff from the
interagency group established to help managers implement the plan.
We also contacted officials or reviewed documents from (1) the Forest
Service's Pacific Northwest (Region 6) and Pacific Southwest (Region
5) offices and its Pacific Northwest Research Station, (2) BLM's
California and Oregon state offices, and (3) Agriculture's Office of
Forestry and Economic Assistance. In addition, we spoke with
officials from (1) the Department of the Interior's Fish and Wildlife
Service and (2) the Department of Commerce's National Marine
Fisheries Service about issues pertaining to the Endangered Species
Act. We also spoke with officials from (1) the Environmental
Protection Agency, (2) Interior's Bureau of Indian Affairs, and (3)
the Small Business Administration about issues pertaining to
interagency coordination and cooperation. Finally, we also met with
and obtained information from representatives of environmental groups
and timber industry organizations.
For our review of the Interior Columbia Basin Ecosystem Management
Project, we examined proposed management alternatives in draft
environmental impact statements. In the course of our work, we also
met with and obtained documents provided by project managers and
staff, including the past and current team leaders. We also spoke
with and obtained information relevant to the proposed plan from
environmental groups, industry, county associations, and a Forest
Service employee group.
We performed our work from September 1997 through March 1999 in
accordance with generally accepted government auditing standards. We
obtained comments on a draft of this report from senior regional
officials responsible for the two plans. These comments and our
responses are presented in appendixes III and IV.
MAJOR CONTRIBUTORS TO THIS REPORT
========================================================== Appendix VI
ENERGY, RESOURCES, AND SCIENCE
ISSUES
Ross Campbell
Charles S. Cotton
Charles T. Egan
Elizabeth R. Eisenstadt
Cheryl Pilatzke
OFFICE OF THE GENERAL COUNSEL
Doreen Stolzenberg Feldman
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