Forest Service: Broad-Scale Assessments Could Be Better Integrated Into
the Forest Planning Process (Testimony, 04/11/2000, GAO/T-RCED-00-146).

Pursuant to a congressional request, GAO discussed the Forest Service's
forest plans, focusing on the: (1) role of broad-scale assessments in
the agency's planning process; (2) lessons that have been learned about
conducting such assessments; and (3) importance of holding Forest
Service managers accountable for integrating the assessments into their
planning processes.

GAO noted that: (1) broad-scale assessments now fill a critical void
that existed in the Forest Service's planning process as it developed
its initial set of forest plans between 1979 and 1995; (2) during that
period, the agency lacked the ability to adequately address ecological,
economic, and social issues that extended beyond the boundaries of the
national forests; (3) without this ability, the planning process was
often characterized by inefficiency and waste as individual national
forests independently attempted to gather and analyze often
noncomparable data and parties successfully challenged forest plans and
projects, causing the Forest Service to delay, amend, and withdraw them;
(4) as the Forest Service has begun incorporating broad-scale
assessments into its forest plans, it has been more successful in
identifying and analyzing these issues and in defining management
alternatives; (5) experience with broad-scale assessments to date has
shown that they need to include certain key elements in order to
maximize their value in helping managers reach decisions on how best to
manage federal lands and resources; (6) in particular, as GAO found in a
review of assessments in the northwest and the Great Lakes, the Forest
Service needs to have clear objectives, identifiable products, firm
deadlines, and realistic cost estimates; (7) experience has shown that
they need to: (a) be open and accessible to all interested and affected
federal and nonfederal parties; (b) occur early in the process of
amending or revising a forest plan so that issues can be identified,
data gathered and analyzed, and conclusions drawn before management
alternatives are identified and proposed; and (c) identify the range of
ecologically viable and legally sufficient management alternatives, but
not result in decisions; (8) in amending or revising the plans, the
Forest Service managers need to address ecological and socioeconomic
issues that extend beyond the boundaries of national forests; (9)
despite the recognized benefits of broad-scale assessments in addressing
these issues, some Forest Service officials still do not view
assessments as a priority, and have not been held accountable for doing
assessments properly; and (10) thus, they have not provided the
leadership, guidance, and funding necessary to complete an assessment in
a timely manner.

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

 REPORTNUM:  T-RCED-00-146
     TITLE:  Forest Service: Broad-Scale Assessments Could Be Better
	     Integrated Into the Forest Planning Process
      DATE:  04/11/2000
   SUBJECT:  Forest management
	     Wildlife conservation
	     Strategic planning
	     National forests
	     Data collection
	     Accountability
	     Environmental monitoring
IDENTIFIER:  Great Lakes
	     Michigan
	     Minnesota
	     Wisconsin

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GAO/T-RCED-00-146

Testimony

Before the Subcommittee on Forests and Forest Health, Committee on
Resources, House of Representatives

For Release on Delivery
Expected at 2:00 p.m., EDT
Tuesday, April 11, 2000

FOREST SERVICE

Broad-Scale Assessments Could Be Better Integrated Into the Forest Planning
Process

Statement of Barry T. Hill,
Associate Director,
Energy, Resources, and Science Issues,
Resources, Community, and Economic Development Division

GAO/T-RCED-00-146Madam Chairman and Members of the Subcommittee:

We are pleased to be here today to discuss the integration of broad-scale
assessments into the process used by the Department of Agriculture's Forest
Service to amend or revise its forest plans. Broad-scale assessments collect
and analyze data and then draw conclusions about issues and conditions that
extend beyond the administrative boundaries of national forests. These
issues can be ecological--such as the threat of catastrophic wildfire,
infestations by insects and disease, and the health of wide-ranging
species-or socioeconomic-such as the supply of timber or recreational
opportunities.

Our statement will summarize (1) the role of broad-scale assessments in the
agency's planning process, (2) the lessons that have been learned about
conducting such assessments, and (3) the importance of holding Forest
Service managers accountable for integrating the assessments into their
planning processes. Our comments are based primarily on two reports issued
within the last year.

In summary, Madam Chairman:

   * Broad-scale assessments now fill a critical void that existed in the
     Forest Service's planning process as it developed its initial set of
     forest plans between 1979 and 1995. During that period, the agency
     lacked the ability to adequately address ecological, economic, and
     social issues that extended beyond the boundaries of the national
     forests. Without this ability, the planning process was often
     characterized by inefficiency and waste as individual national forests
     independently attempted to gather and analyze often noncomparable data
     and parties successfully challenged forest plans and projects, causing
     the Forest Service to delay, amend, and withdraw them. As the Forest
     Service has begun incorporating broad-scale assessments into its forest
     plans, it has been more successful in identifying and analyzing these
     issues and in defining management alternatives.
   * Experience with broad-scale assessments to date has shown that they
     need to include certain key elements if they are to maximize their
     value in helping managers reach decisions on how best to manage federal
     lands and resources. In particular, as we found in our review of
     assessments in the northwest and the Great Lakes, they need to have
     clear objectives, identifiable products, firm deadlines, and realistic
     cost estimates. Experience has also shown that they need to:

--be open and accessible to all interested and affected federal and
nonfederal parties;

--occur early in the process of amending or revising a forest plan so that
issues can be identified, data gathered and analyzed, and conclusions drawn
before management alternatives are identified and proposed; and

--identify the range of ecologically viable and legally sufficient
management alternatives, but not result in decisions.

   * Our work over the past 5 years has shown that in amending or revising
     their plans, Forest Service managers need to address ecological and
     socioeconomic issues that extend beyond the boundaries of national
     forests. Doing so is necessary for them to comply with laws such as the
     Endangered Species Act and the National Environmental Policy Act. Yet
     despite the recognized benefits of broad-scale assessments in
     addressing these issues, some Forest Service officials still do not
     view assessments as a priority, and have not been held accountable for
     doing assessments properly. Thus, they have not provided the
     leadership, guidance, and funding necessary to complete an assessment
     in a timely manner. For instance, in our opinion, the Forest Service
     has not effectively integrated the assessment for the Great Lakes into
     its process for revising forest plans in the Lake States region of
     Michigan, Minnesota, and Wisconsin. As a result, the process may be
     vulnerable to the same inefficiency and waste that earlier plagued
     forest plans.

To address this problem, we recommended in our February 2000 report that the
Forest Service revise its planning regulations to maximize the value of
broad-scale assessments and better integrate them into its planning process.
While the Forest Service generally agreed with us that assessments are an
important component of the forest planning process, it did not agree with
our recommendations. For example, the Forest Service has chosen to leave the
decision on whether to conduct an assessment to the discretion of its
independent and highly autonomous forest offices. Nor does the agency plan
to revise its planning regulations to spell out the characteristics that we
believe are essential for a successful assessment. We continue to believe
that following these recommendations would increase the likelihood that
assessments would be properly done.

Broad-Scale Assessments Fill a Critical Void in the Forest Service's
Planning Process

To be useful, the Forest Service's planning process needs to help land
managers make decisions about a spectrum of issues, both local-such as the
placement of a campsite-and regional-such as the quantity of old-growth
forest. In the past, the Forest Service's planning process did not
adequately address ecological issues-from costly outbreaks of wildfires,
insects, and diseases; invasions of exotic weeds; declines in soil fertility
and water and air quality; and the habitat requirements of wide-ranging rare
species, such as anadromous fish, the grizzly bear, and the lynx-that often
extend beyond forest boundaries. Similarly, the process did not adequately
address social and economic issues-including the flow of timber, livestock
forage, and other commodities as well as the growing demand for developed
and dispersed recreation opportunities-that increasingly require the Forest
Service to look beyond its jurisdiction for solutions.

The initial set of forest plans-from 1979 to 1995-was costly and
time-consuming to develop, and the agency often failed to achieve planned
objectives. These difficulties occurred, in part, because the agency lacked
the data and technology to adequately address broad-scale ecological and
socioeconomic issues. As a result, broad-scale assessments were not
conducted and/or individual national forests independently attempted to
gather and analyze often noncomparable data. Plans and projects developed
without sound information on broad-scale issues have been challenged for not
satisfying the requirements of environmental and other laws--including the
Endangered Species Act and the National Environmental Policy Act--and courts
have required the agency to delay, amend, or withdraw them. Moreover,
inefficiency and waste within the planning and decision-making process,
including the need to respond to legal challenges, have cost taxpayers
hundreds of millions of dollars.

As the Forest Service continues to revise the forest plans, we believe it is
essential that it improves how it addresses issues that extend beyond the
boundaries of national forests. During the past decade, the Forest Service
has taken several steps to improve its planning process in a way that will
enable it to address these issues. For example, the agency has begun to use
broad-scale assessments to (1) support decisions that apply simultaneously
to multiple forests, such as those in the Pacific Northwest and the interior
Columbia River basin and (2) revise individual forest plans, such as those
for the Great Lakes region and the southern portion of the Appalachian
Mountains. The agency has also begun to use satellite imagery, geographic
information systems, and desktop computer technology to gather, interpret,
and manipulate detailed data to support the assessments.

Lessons Learned About Conducting Broad-Scale Assessments Increase Their
Value to Forest Planning

Early efforts to integrate broad-scale assessments into the processes being
used by the Forest Service to amend or revise forest plans have provided
useful lessons to the Forest Service and others about conducting such
assessments. These lessons learned--or best practices-demonstrate that to be
most useful an assessment must have clear objectives, identifiable products,
firm deadlines, and realistic cost estimates and be open and accessible to
all interested and affected federal and nonfederal parties.

For instance, broad-scale assessments can save both time and money if they
eliminate duplicative data gathering and analysis by individual national
forests, make data gathered by a variety of federal and nonfederal
organizations more comparable, and/or increase the likelihood that the
Forest Service will avoid or prevail against challenges to its plans and
projects. However, the time and costs to do an assessment can vary widely
depending on the number and complexity of the issues to be addressed, the
amount of data to be gathered and analyzed, and the types of products to be
delivered. For example, the assessment for the Pacific Northwest, which
focused primarily on one issue-the northern spotted owl and other
old-growth-dependent species-was completed in about 3 months and cost less
than $3.5 million. By contrast, the assessment for the interior Columbia
River basin--which addressed numerous ecological and socioeconomic
issues--took several years and cost about $22.7 million. Federal funding and
resources may not always be sufficient to cover all of the issues that could
be addressed or to gather and analyze all of the potentially limitless
ecological, economic, and social data that are available. Therefore,
realistic objectives and estimates of resource needs-and of what products
can be expected from an assessment given different funding levels-need to be
identified before an assessment is begun.

On the basis of our review, we believe that the Forest Service also needs to
make funding decisions in advance in order to accomplish an assessment's
objectives. For example, the assessments for the Pacific Northwest and the
interior Columbia River basin were identified for special funding in the
Forest Service's fiscal year budget justifications, and money was withheld
from the forests' annual budgets to fund the assessments. Conversely, the
assessment for the Great Lakes has not had a secure source of funding.
Instead, it has relied on funding from a variety of sources at various times
for a variety of purposes. As a result, the assessment's objectives have, at
one time or another, been expanded to include activities that do not
directly support the Lake States national forests in revising their plans
and contracted to exclude other activities that would assist them in
reaching more informed decisions.

Regardless of their scope of work, we and others who have reviewed
assessments believe that they must occur early in the process to amend or
revise a forest plan if they are to be useful to decisionmakers. That way,
issues can be identified, data gathered and analyzed, and conclusions drawn
before management alternatives are identified and proposed. However, the
Forest Service has not always effectively integrated assessments into the
process for amending or revising forest plans. For example, the assessment
and the development of alternatives for managing Forest Service and other
federal lands in the interior Columbia River basin were conducted
concurrently, contributing to the false starts and delays that have plagued
the planning process for that region.

Similarly, problems with the timing of the Great Lakes assessment have
limited its effectiveness. In November 1999, several years after the Lake
States national forests had begun to revise their forest plans and about a
year before they were scheduled to issue draft management alternatives, they
asked the Great Lakes assessment team to provide substantial additional
information and analysis to support revisions to their plans. This included
information on broad-scale issues identified by the forests as being
important 4 years earlier, such as timber supply and habitat fragmentation.
Only after this November 1999 request did the forest supervisors and the
assessment team leader meet to discuss products, schedules, and costs for
obtaining specific types of data and analyses the forests would need to
finish revising their plans. The assessment team is not able to provide all
of the data and analysis by the time they are needed under the current
funding and staffing levels, according to the assessment team leader. In
retrospect, officials responsible for the interior Columbia River basin plan
and on the Great Lakes assessment team agree that an assessment should be
completed before-rather than concurrently or after--planners identify and
propose a range of management alternatives.

While assessments should help to identify the range of ecologically viable
and legally sufficient management alternatives and should provide the
information that people need for a productive discussion of the issues, they
have not and should not result in decisions. As the Forest Service and
others have observed, the mix of products and services provided on federal
lands "is as much a social decision as it is a scientific one" and
trade-offs among ecologically viable and legally sufficient management
alternatives are ultimately made by society.

The Forest Service Should Hold Its Officials Accountable for Integrating
Broad-Scale Assessments Into The Planning Process

In amending or revising their plans, Forest Service officials need to
address ecological and socioeconomic issues that extend beyond the
boundaries of national forests in order to comply with existing
environmental and procedural laws. However, despite the recognized benefits
of broad-scale assessments in addressing these issues, some Forest Service
officials still do not view assessments as a priority. Thus, they have not
always provided the leadership, guidance, and funding necessary to complete
assessments in a timely manner.

For instance, in our opinion, Forest Service officials do not view the Great
Lakes assessment as a priority and have not effectively integrated it into
the process for revising forest plans in the Lake States. The agency's
headquarters has not provided the region with any written guidance or
directives on when to conduct an assessment or how to use its products. The
region, in turn, has taken a "hands-off" approach and given the individual
forest supervisors the discretion to use or not use the assessment as they
see fit. Some forest supervisors told us that they were reluctant to support
the assessment and some told us that they expected it to fail, so they
provided only modest seed money to begin the assessment and/or sought to
limit its scope by limiting its funding. As a result, the assessment team
has had to seek funding from other sources and assume leadership by default.

On October 5, 1999, the Forest Service proposed revisions to its forest
planning regulations. In light of the consensus on the value of broad-scale
assessments in amending or revising forest plans and the lack of priority
given by the agency to assessments, we see this effort as an opportunity to
better integrate the assessments into the agency's process for amending or
revising forest plans. Toward this end, our February 2000 report on
broad-scale assessments included recommendations that, if implemented, would
better ensure that assessments are effectively used in amending or revising
forest plans. Specifically, we recommended that the regulations make clear
that broad-scale assessments must be used in revising forest plans unless
the region(s) and forest(s) can justify their omission. We also recommended
that the regulations provide that when a decision is made to conduct an
assessment, the region(s) and forest(s) must prepare a strategy that
identifies, among other things, (1) how the assessment will be linked to the
forest plan revision process, (2) how other governmental entities and the
public will participate in the assessment, (3) what objectives the
assessment will meet and what products it will generate, including those of
the highest priority, and (4) how much the assessment will cost, how funding
will be secured for it, and what is likely to happen if full funding is not
available. These steps would also help hold Forest Service managers
accountable for integrating broad-scale assessments into their planning
processes and would institutionalize the lessons learned to date.

Although the Forest Service agreed with the desired outcome of our
recommendations, it did not agree to revise the proposed planning
regulations to make an assessment the rule rather than the exception in
amending or revising a forest plan. The Forest Service believes that this is
unnecessary because the intent of the proposed regulations is to base
decisions on scientific data, including broad-scale data when appropriate.
As a result, the regulations would generally leave the decision on whether
to conduct an assessment to the discretion of the agency's individual forest
supervisors.

Similarly, the agency does not plan to revise the proposed planning
regulations to incorporate all of the lessons learned to date about
integrating broad-scale assessments into its planning process, preferring
instead to place such guidance in its manuals and directives. As a result,
the proposed regulations (1) do not state when in the planning process an
assessment should occur, (2) are silent on the need for clear objectives and
identifiable products, and (3) do not require the forests to identify their
strategies for involving the public if an assessment is done.

Madam Chairman, as we have pointed out to you before, the Forest Service
often agrees with the intent of our recommendations, but leaves their
implementation to the discretion of its independent and highly autonomous
regional and forest offices, which produces mixed results. We are concerned
that the Forest Service will continue to allow individual forest supervisors
to use or not to use broad-scale assessments as they see fit without having
to first weigh their benefits and costs. We are also concerned that this
pattern of behavior, if applied to implementation of broad-scale
assessments, could diminish their potential and ultimately represent a lost
opportunity.

Madam Chairman, that concludes my formal statement. If you or other Members
of the Subcommittee have any questions, we will be pleased to respond to
them.

Contact and Acknowledgment

For future contacts regarding this testimony, please contact Barry T. Hill
on (202) 512-3841. Individuals making key contributions to this testimony
and/or to the two reports on which it was primarily based include Ross
Campbell, Charles S. Cotton, Charles T. Egan, Elizabeth R. Eisenstadt,
Doreen Stolzenberg Feldman, Dena M. Owens, and Cheryl Pilatzke.

(141437)

  
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