Forest Service: Issues Related to Managing National Forests for Multiple
Uses (Testimony, 03/26/96, GAO/T-RCED-96-111).

Pursuant to a congressional request, GAO provided information on the
Forest Service's management of national forests, focusing on the issues
related to multiple use of forest land. GAO noted that: (1) the Forest
Service's decisions are affected by changing natural land conditions,
funding, and new information and events; (2) laws concerning forest land
use are complicated by fragmented authority between federal agencies and
states; (3) the Forest Service should consider shortening the periods
covered under forest plans, reducing the influence of subsequent events,
improving the data on which decisions are based, increasing coordination
among the Forest Service and other federal agencies, and limiting
administrative appeals; (4) some Forest Service officials believe that
Congress should provide guidance on how to balance competing uses of
forest land; and (5) the Chief of the Forest Service believes that the
maintenance and restoration of noncommodity uses should be explicitly
accepted or rejected, and if accepted, the effects should be
acknowledged.

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

 REPORTNUM:  T-RCED-96-111
     TITLE:  Forest Service: Issues Related to Managing National Forests 
             for Multiple Uses
      DATE:  03/26/96
   SUBJECT:  National forests
             Forest management
             Environmental policies
             Interagency relations
             Public lands
             Forest conservation
             Timber sales
IDENTIFIER:  Oregon
             California
             Washington
             
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Cover
================================================================ COVER


Before the Subcommittee on National Parks, Forests, and Lands, U.S. 
House of Representatives

For Release on Delivery
Expected at
10:00 am EST
Tuesday
March 26, 1996

FOREST SERVICE - ISSUES RELATED TO
MANAGING NATIONAL FORESTS FOR
MULTIPLE USES

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

GAO/T-RCED-96-111

GAO/RCED-96-111T


(140344)


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

  GAO -
  NEPA -
  NFMA -
  OTA -

============================================================ Chapter 0

Mr.  Chairman and Members of the Subcommittee: 

We are pleased to be here today to discuss our ongoing review for you
and other requesters of the decisionmaking process used by the
Department of Agriculture's Forest Service in carrying out its
mission.  By law, the Forest Service is to manage its lands for
multiple uses, including timber, livestock forage, recreation, fish
and wildlife, wilderness, and water supply.  In doing so, the Forest
Service is expected to sustain undiminished the lands' productivity
for future generations while providing for high levels of these uses. 
To meet its legislative mandate, the Forest Service uses a
decisionmaking process that includes (1) developing management plans,
commonly called forest plans, and (2) reaching project-level
decisions for implementing these plans. 

In testifying on January 25, 1996, before the Subcommittee on Forests
and Public Land Management, Senate Committee on Energy and Natural
Resources,\1 we stated that although the current forest plans include
goals, related objectives, and schedules for implementing the
objectives over 10 to 15 years, the Forest Service often has not been
able to achieve the objectives during the periods covered by the
plans. 

Some in the Congress have expressed concern about the ability of the
Forest Service to provide a high degree of confidence that it can
achieve the forest plans' objectives during the periods covered by
the plans.  They have also expressed concern about the increasing
difficulty the Forest Service is experiencing in resolving conflicts
among competing uses, especially between commodity uses, such as
timber and livestock forage, and noncommodity uses, including
recreation, fish and wildlife, wilderness, and water supply. 

As agreed, our testimony today provides preliminary information on
(1) options that may help the Forest Service to achieve the
objectives in its forest plans and (2) the increasing difficulty, for
the Forest Service, of resolving conflicts among competing uses.  We
will complete a thorough analysis of the Forest Service's
decisionmaking process and issue a report later this year that will
include any conclusions and recommendations that we may have. 

In summary, Mr.  Chairman, the information that we have gathered to
date suggests the following: 

  Many variables affect the outcomes of the Forest Service's
     decisions, including changing natural conditions and funding, as
     well as new information and events.  In addition, some Forest
     Service officials believe that differences among the
     requirements and limitations in laws and regulations can
     sometimes be difficult to reconcile, and that reconciliation is
     further complicated by the fragmentation of authority for
     implementing these laws and regulations among several federal
     agencies and the states.  A systematic and comprehensive
     approach will be needed to address these issues.  Some options
     that may be considered in developing such an approach include
     (1) shortening the periods covered by the plans, (2) reducing
     the influence of subsequent events, (3) linking forest plans to
     funding, (4) improving the data on which decisions are based,
     (5) improving coordination between the Forest Service and other
     federal agencies, and (6) limiting administrative appeals. 

  While these options may improve the ability of the Forest Service
     to provide a higher degree of confidence concerning the future
     availability of uses on national forest lands, they are unlikely
     to resolve the increasing difficulty the Forest Service is
     experiencing in reconciling conflicts among competing uses.  As
     a result of these conflicts, some Forest Service officials have
     suggested that the Congress needs to provide greater guidance on
     how the agency is to balance competing uses.  In particular, the
     Chief of the Forest Service has stated that (1) the maintenance
     and restoration of noncommodity uses, especially the diversity
     of native plant and animal communities (biological diversity),
     needs to be explicitly accepted or rejected and (2) if accepted,
     its effects on the availability of commodity uses should be
     acknowledged. 


--------------------
\1 Forest Service:  Issues Relating to Its Decisionmaking Process
(GAO/T-RCED-96-66, Jan.  25, 1996). 


   BACKGROUND
---------------------------------------------------------- Chapter 0:1

The Forest Service, created in 1905, manages about 192 million acres
of land that include about one-fifth of the nation's forest lands. 
The Organic Administration Act of 1897 and the Multiple Use-Sustained
Yield Act of 1960 guide the management of these lands.  The Forest
Service is to manage its lands under the principles of multiple use
and sustained yield to meet people's diverse needs. 

The Congress mandated forest plans in the Forest and Rangeland
Renewable Resources Planning Act of 1974, as amended by the National
Forest Management Act of 1976 (NFMA).  NFMA provides guidance for
forest planning by delineating a procedure to be followed in
developing and periodically revising or amending forest plans.  Under
this act and its implementing regulations, the Forest Service is to,
among other things, (1) involve the public in the planning process,
(2) recognize wilderness as a use of the forests, (3) maintain
biological diversity, (4) monitor and assess the effects of its
management practices on the lands' productivity, and (5) ensure a
sustained yield of timber. 

The last of the 123 forest plans covering all 155 forests in the
National Forest System was approved in 1995, and the first plans,
approved in the early 1980s, are due for revision.  The plans
identify (1) different management areas or "zones" within a forest
where one or more uses will be permitted for up to 15 years and (2)
requirements and limitations for protecting the environment, such as
those to protect species listed as endangered or threatened under the
Endangered Species Act.  Forest plans are implemented by identifying,
analyzing, and undertaking specific projects, which must be
consistent with the requirements and limitations in the plans. 

In developing forest plans and reaching project-level decisions, the
Forest Service must comply with the requirements of the National
Environmental Policy Act (NEPA).  NEPA and its implementing
regulations specify the procedures for integrating environmental
considerations into an agency's decisionmaking.  Forest plans and
projects must also comply with the requirements and implementing
regulations of numerous environmental statutes, including the
Endangered Species Act, the Clean Water Act, and the Clean Air Act. 


   OPTIONS THAT MAY HELP ACHIEVE
   FOREST PLAN OBJECTIVES
---------------------------------------------------------- Chapter 0:2

In a 1992 report,\2 the Office of Technology Assessment (OTA) stated
that, to improve forest planning under NFMA, the Congress could
require the Forest Service to specify objectives (targets) for all
uses in its forest plans.  However, some Forest Service officials
believe that if the agency is to achieve the objectives in its forest
plans, other changes may be needed to reduce the influence of many
variables that affect the outcomes of its decisions.  These variables
include changing natural conditions, such as drought, insects and
disease, and wildfires, as well as changes in annual funding for the
National Forest System.  They also include information and events
that occur after forest plans have been approved.  In addition,
Forest Service policy and planning officials believe that differences
among the requirements and limitations in laws and regulations can
sometimes be difficult to reconcile, and that reconciliation is
further complicated by the fragmentation of authority for
implementing these laws and regulations among several federal
agencies and the states. 

As we stated in our January 25, 1996, testimony, because the Forest
Service's decisionmaking process is extremely complex and the issues
surrounding it are interrelated, there are no quick fixes or simple
solutions.  Rather, a systematic and comprehensive approach will be
needed to address them.  Some options that may be considered in
developing such an approach may help the Forest Service to achieve
the objectives in its forest plans.  Some of these options could be
implemented by the Forest Service within the existing statutory
framework, while others would require changes in law. 


--------------------
\2 Forest Service Planning:  Accommodating Uses, Producing Outputs,
and Sustaining Ecosystems (OTA-F-505, Washington, D.C.:  Feb.  1992). 


      SHORTENING PLANNING PERIODS
-------------------------------------------------------- Chapter 0:2.1

Forest plans generally take from 3 to 10 years to develop and explain
how forests will be managed for 10 to 15 years.  Much can change over
such extended periods of time.  As a result, forest plans can be
outdated by the time they are approved, and schedules for
implementing the plans' objectives cannot be established for 10 to 15
years.  Options that have been suggested include shortening both (1)
the time required to develop the plans and (2) the periods covered by
the plans to 3 to 5 years.  One drawback to shortening the periods
covered by forest plans may be that 3 to 5 years might not provide
companies and communities dependent on Forest Service lands with
enough time to plan or develop long-range investment strategies. 


      REDUCING THE INFLUENCE OF
      SUBSEQUENT EVENTS
-------------------------------------------------------- Chapter 0:2.2

In addition, according to some Forest Service officials, events that
occur after forest plans have been approved can significantly affect
the agency's ability to provide a high degree of confidence
concerning the future availability of uses on national forest lands. 
These events can include listing a species as endangered or
threatened or designating land as habitat under the Endangered
Species Act,\3 changing timber harvesting methods in response to
increased environmental restrictions,\4 and evolving judicial
interpretations of procedural requirements in environmental statutes. 

For example, Forest Service officials note that recent federal court
decisions have required the agency to re-initiate lengthy, formal
consultations on several approved forest plans because a species of
salmon was listed as threatened in the Pacific Northwest and the
Mexican Spotted Owl was listed as threatened in the Southwest.  These
rulings have prohibited the agency from implementing projects under
these plans until the new round of consultations has been completed,
even though the Forest Service believes that some of the projects
would have no effect on these species.  These Forest Service
officials believe that the Congress should provide legislative
clarification so that projects unaffected by a subsequent event would
not have to be delayed by the lengthy process to amend or revise
forest plans. 


--------------------
\3 Private Timberlands:  Private Timber Harvests Not Likely to
Replace Declining Federal Harvests (GAO/RCED-95-51, Feb.  16, 1995). 

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


      LINKING FOREST PLANS TO
      FUNDING
-------------------------------------------------------- Chapter 0:2.3

Forest Service officials also believe that annual appropriations have
not always matched the funding assumptions incorporated in forest
plans.  This lack of connection has occurred, in part, because some
forest plans have been developed without reference to likely funding
levels.  Options that have been suggested include linking forest
plans more closely to budgeting and including objectives for
commodity and noncommodity uses at various funding levels in forest
plans.  According to these officials, a possible complementary
statutory option would be to appropriate funds for the duration of a
shortened planning period. 


      IMPROVING DATA
-------------------------------------------------------- Chapter 0:2.4

The process currently used to reach project-level decisions for
implementing forest plans may also have to be shortened.  For
example, preparing timber sales usually takes 3 to 8 years.\5

One option that might shorten the time required to reach
project-level decisions would be to obtain better data to use in
developing forest plans.  Prior GAO reports have shown that the goals
and objectives in some forest plans were developed using inadequate
data and inaccurate estimating techniques.\6 Information subsequently
gathered at the project level showed that certain objectives in the
plans could not be met. 

In addition, the Forest Service established a re-engineering team,
consisting primarily of regional and forest-level personnel, and
tasked the team with designing a new process for conducting
project-level environmental analyses.  According to this team, the
agency is currently gathering and analyzing information at the
project level that should have been analyzed at the forest plan
level.  Gathering and analyzing information in this manner is both
time-consuming and costly and can result in delayed, modified, or
withdrawn projects.\7

The re-engineering team has made several recommendations whose
implementation, it believes, would produce more timely and adequate
information.  These recommendations include (1) identifying issues
that should be analyzed and resolved in forest plans or other
broader-scale studies, (2) maintaining a centralized system of
comparable environmental information, and (3) eliminating redundant
analyses by focusing on what is new and using existing analyses to
support new decisions when possible.  In addition, Forest Service
officials have told us that some effects cannot be adequately
determined in advance of a project-level decision because of
scientific uncertainty and/or the prohibitive costs of obtaining the
necessary data.  Therefore, they believe that, for some projects,
monitoring and evaluation could be more efficient and effective than
attempting to predict the projects' outcomes. 

The Forest Service is currently evaluating the findings and
recommendations that the re-engineering team believes could improve
timeliness and reduce costs by 10 to 15 percent initially and by 30
to 40 percent over time.  The agency is also considering or testing
other actions that it believes could make its project-level
environmental analysis process more efficient, including improving
the monitoring and evaluation of decisions. 


--------------------
\5 See footnote 4. 

\6 See footnote 4 and Forest Service:  The Flathead National Forest
Cannot Meet Its Timber Goal (GAO/RCED-91-124, May 10, 1991). 

\7 Final Report of Recommendations:  Project-Level Analyses
Re-Engineering Team (Nov.  17, 1995). 


      IMPROVING INTERAGENCY
      COORDINATION
-------------------------------------------------------- Chapter 0:2.5

According to Forest Service officials with whom we spoke, another
difficulty at both the forest plan and project levels is that the
authority to implement various environmental laws and regulations is
fragmented among several federal agencies and the states.  In
developing forest plans and reaching project-level decisions, the
Forest Service often must consult with other federal agencies,
including the Department of the Interior's Fish and Wildlife Service,
the Department of Commerce's National Marine Fisheries Service, the
Environmental Protection Agency, and/or the U.S.  Army Corps of
Engineers.  These agencies sometimes disagree on how environmental
requirements can best be met in a forest plan or project, and they
have difficulty resolving their disagreements, thereby delaying
decisionmaking.  According to federal officials with whom we spoke,
these disagreements often stem from differences in the agencies'
evaluations of environmental effects that tend to reflect the
agencies' disparate missions and responsibilities.  The officials
believe that, to resolve these disagreements more quickly, they would
need to place greater reliance on monitoring and evaluating the
effects of prior decisions to derive guidance for future decisions on
similar projects. 

Additionally, the Forest Service and other federal agencies recently
have signed various memoranda of agreement to improve coordination. 
However, not enough time has passed to evaluate the effects of these
agreements. 


      LIMITING ADMINISTRATIVE
      APPEALS
-------------------------------------------------------- Chapter 0:2.6

The Forest Service receives over 1,200 administrative appeals to
project-level decisions annually by parties seeking to delay, modify,
or stop projects with which they disagree.  While believing that
appeals and litigation are legitimate ways for the Forest Service to
resolve substantive conflicts and support its NEPA policy, the
re-engineering team tasked with designing a new process for
project-level environmental analyses recommended amending the current
law and regulations to limit such appeals to the parties who
participate in the decisionmaking process and to the concerns that
are raised in reaching a decision.  By establishing participation as
a condition for appealing a decision, this change might increase
public participation in the Forest Service's project-level
decisionmaking process. 


   CONFLICTS AMONG COMPETING USES
---------------------------------------------------------- Chapter 0:3

While these options may improve the ability of the Forest Service to
provide a higher degree of confidence concerning the future
availability of forest uses on national forest lands, they are
unlikely to resolve the increasing difficulty the Forest Service is
experiencing in reconciling conflicts among competing uses.  For
example, in its 1992 report, OTA stated that "Congressional efforts
to change the judicial review process seem to be attempts to resolve
substantive issues without appearing to take sides.  However, such
changes are unlikely to improve forest planning or plan
implementation, or reduce conflict over national forest management."

In the past, the Forest Service was able to meet the diverse needs of
the American people because it could avoid, resolve, or mitigate
conflicts between commodity and noncommodity uses by separating them
among areas and over time.  For example, while timber harvesting was
forbidden in wilderness areas and was secondary to other uses, such
as recreation and wildlife, in some other areas, it was the dominant
use in still other areas.  Alternatively, the Forest Service
sometimes avoided conflicts by using the same land for different
commodity and noncommodity uses, but at different times.  For
example, it sometimes used harvested timberlands as browsing and
hiding habitat for game animals while the lands were being reforested
for subsequent harvests. 

However, according to Forest Service officials, the interaction of
legislation, regulation, case law, and administrative direction,
coupled with growing demands for commodity and noncommodity uses on
Forest Service lands and activities occurring outside forest
boundaries--such as harvesting timber on state timberlands and
converting private timberlands to agricultural and urban uses\8
--have made simultaneously meeting all of these needs increasingly
difficult.  According to the Chief of the Forest Service, the agency
has placed increasing emphasis on maintaining or restoring
noncommodity uses, especially biological diversity, on national
forest lands, and this emphasis has significantly affected the
agency's ability to meet the demands for commodity uses. 

For example, increasing amounts of national forest land are being
managed primarily for conservation, as wilderness, wild and scenic
rivers, and recreation.  In 1964, less than 9 percent (16 million
acres) of national forest land was managed for conservation.  By
1994, this figure had increased to 26 percent (almost 50 million
acres).\9

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

These figures do not take into account additional environmental
restrictions that have reduced the amount of federal land available
for commodity uses.  For example, another 7.6 million acres, or 31
percent, of federal land in western Washington, Oregon, and
California that were available for commercial timber harvest have
been set aside or withdrawn as habitat for species that live in
old-growth forests, including the threatened northern spotted owl,
and for riparian reserves to protect watersheds.  Limited timber
harvesting and salvage are allowed in some of these areas for forest
health. 

In total, 77 percent of the 24.5 million acres of federal land in
western Washington, Oregon, and California that were available for
commercial timber harvest have been set aside or withdrawn primarily
for noncommodity uses.  In addition, while the remaining 5.5 million
acres, or 22 percent, are available for regulated harvest, minimum
requirements for maintaining biological diversity under NFMA as well
as air and water quality under the Clean Air and Clean Water acts,
respectively, may limit the timing, location, and amount of
harvesting that can occur.  Moreover, harvests from these lands could
be further reduced by plans to protect threatened and endangered
salmon.\10

Timber sold from Forest Service lands in the three states declined
from 4.3 billion board feet in 1989 to 0.9 billion board feet in
1994, a decrease of about 80 percent.  However, as we noted in an
August 1994 report,\11 many agency officials, scientists, and natural
resource policy analysts believe that maintaining or restoring
wildlife and their physical environment is critical to sustaining
other uses on Forest Service lands. 

As the Forest Service noted in October 1995,\12 demands for forest
uses, both commodity and noncommodity, will increase substantially in
the future.  Thus, as we noted in our January 25, 1996, testimony,
some Forest Service officials do not believe that the conflicts among
competing uses will lessen substantially.  As a result, some Forest
Service officials have suggested that the Congress needs to provide
greater guidance on how the agency is to balance competing uses.  In
particular, the Chief has stated that (1) the maintenance and
restoration of noncommodity uses, especially biological diversity,
needs to be explicitly accepted or rejected and (2) if accepted, its
effects on the availability of commodity uses should be acknowledged. 


--------------------
\8 See footnote 3. 

\9 Land Ownership:  Information on the Acreage, Management, and Use
of Federal and Other Lands (GAO/RCED-96-40, Mar.  13, 1996). 

\10 See footnote 3. 

\11 Ecosystem Management:  Additional Actions Needed to Adequately
Test a Promising Approach (GAO/RCED-94-111, Aug.  16, 1994). 

\12 The Forest Service Program for Forest and Rangeland Resources:  A
Long-Term Strategic Plan, Draft 1995 RPA Program, Oct.  1995. 


-------------------------------------------------------- Chapter 0:3.1

In summary, Mr.  Chairman, I would like to offer the following
observation.  As indicated by the GAO products referred to in this
statement, we have over the last several years looked at the Forest
Service from several different perspectives and at several
organizational levels.  What is becoming more apparent is that,
regardless of the organizational level and the perspective from which
the agency is viewed, many of the issues appear to be the same. 
These issues include the lack of (1) adequate scientific and
socioeconomic data to make necessary or desired trade-offs among
various values and concerns, (2) adequate coordination within the
Forest Service and among federal agencies to address issues and
concerns that transcend the boundaries of ownership and jurisdiction,
and (3) incentives for federal and nonfederal stakeholders to work
together cooperatively to resolve their differences.  We will, in the
coming months, more fully evaluate these and other issues. 

Mr.  Chairman, this concludes my statement.  I would be happy to
respond to any questions that you or Members of the Subcommittee may
have. 

*** End of document. ***