Federal Land Management: Streamlining and Reorganization Issues
(Testimony, 06/27/96, GAO/T-RCED-96-209).

GAO discussed ways to improve the management of federal lands. GAO noted
that: (1) the responsibilities of the National Park Service, Bureau of
Land Management, Fish and Wildlife Service, and Forest Service have
become increasingly similar; (2) federal land management has become
increasingly complex due to the differences among laws and regulations;
(3) federal land management agencies could be more cost efficient and
ecologically effective if they improve their organizational structures
and interagency relationships; (4) the two basic strategies to improve
federal land management include streamlining the management structure by
coordinating and integrating functions, systems, activities, programs,
and field locations, and combining land management agencies; and (5) due
to the lack of consensus for change, no legislation to streamline or
reorganize the federal land management agencies has been enacted.

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

 REPORTNUM:  T-RCED-96-209
     TITLE:  Federal Land Management: Streamlining and Reorganization 
             Issues
      DATE:  06/27/96
   SUBJECT:  Public lands
             National parks
             National forests
             National recreation areas
             Wilderness areas
             Land management
             Federal agency reorganization
             Reengineering (management)
             Interagency relations
             Federal property management

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


Before the Committee on Governmental Affairs,
United States Senate

For Release on Delivery
Expected at
10:00 a.m., EDT
Thursday
June 27, 1996

FEDERAL LAND MANAGEMENT -
STREAMLINING AND REORGANIZATION
ISSUES

Statement of Michael Gryszkowiec,
Director of Planning and Reporting,
Resources, Community, and Economic
Development Division

GAO/T-RCED-96-209

GAO/RCED-96-209T


(140299)


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

  EPA -
  NEPA -

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

Mr.  Chairman and Members of the Committee: 

We are pleased to be here to discuss ways to improve the management
of federal lands.  My observations today are based primarily on
products that we have issued over the last several years on the
activities and programs of the four major federal land management
agencies--the National Park Service, the Bureau of Land Management,
and the Fish and Wildlife Service within the Department of the
Interior and the Forest Service within the Department of Agriculture. 

The federal government owns about 30 percent (about 650 million
acres) of the nation's total surface area.  The four major federal
land management agencies manage about 95 percent of these lands for a
variety of commodity uses--including hardrock mining, livestock
forage, oil and gas exploration and development, and timber
harvesting--and noncommodity uses--including fish and wildlife;
natural, scenic, cultural, and historic resources; recreation; water;
and wilderness.\1

In summary, Mr.  Chairman, our work to date suggests the following: 

  -- The responsibilities of the four major federal land management
     agencies have grown more similar over time.  Most notably, the
     Forest Service and the Bureau of Land Management now provide
     more noncommodity uses, including recreation and protection for
     fish and wildlife, on their lands.  In addition, managing
     federal lands has become more complex.  Managers have to
     reconcile differences among a growing number of laws and
     regulations, and the authority for these laws is dispersed among
     several federal agencies and state and local agencies.  These
     changes have coincided with two other developments--the federal
     government's increased emphasis on downsizing and budgetary
     constraint and scientists' increased understanding of the
     importance and functioning of natural systems whose boundaries
     may not be consistent with existing jurisdictional and
     administrative boundaries.  Together these changes and
     developments suggest a basis for reexamining the processes and
     structures under which the federal land management agencies
     currently operate. 

  -- Over the last 26 years, two basic strategies have been proposed
     to improve federal land management:  (1) streamlining the
     existing structure by coordinating and integrating functions,
     systems, activities, programs, and field locations and (2)
     reorganizing the structure by combining agencies.  The two
     strategies are not mutually exclusive and some prior proposals
     have encompassed both.  However, no significant legislation has
     been enacted on the basis of these proposals. 

  -- Past efforts to improve federal land management have not
     succeeded, in part because they were not supported by a solid
     consensus for change.  In addition, any effort to streamline or
     reorganize the existing structure of federal land management
     will require a coordinated approach within and across agency
     lines to avoid creating new unintended consequences for the
     future.  Moreover, the need to create specific, identifiable
     goals will require decisionmakers to agree on, among other
     issues, how to balance differing objectives for various uses on
     federal lands over the short and long term. 


--------------------
\1 Land Ownership:  Information on the Acreage, Management, and Use
of Federal and Other Lands (GAO/RCED-96-40, Mar.  13, 1996). 


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

Each of the four major federal land management agencies manages its
lands and the resources they contain on the basis of its
legislatively mandated responsibilities.  In general, the Fish and
Wildlife Service and the National Park Service manage their lands
primarily for noncommodity uses.  The Fish and Wildlife Service
manages its lands primarily to conserve and protect fish and wildlife
and their habitat, although other uses--such as recreation (including
hunting and fishing), mining and mineral leasing, livestock grazing,
and timber harvesting--are allowed when they are compatible with the
primary purposes for which the lands are managed.  The National Park
Service manages its lands to conserve, preserve, protect, and
interpret the nation's natural, cultural, and historic resources for
the enjoyment and recreation of current and future generations. 

Conversely, the Forest Service and the Bureau of Land Management are
legislatively mandated to manage their lands for both commodity and
noncommodity uses.  For example, the Forest Service's organic
legislation--the Organic Administration Act of 1897--refers to water
flows and timber supply.  The Multiple Use-Sustained Yield Act of
1960 added responsibilities for recreation, range, and fish and
wildlife and required the agency to manage its lands so as to sustain
all of these uses.  The National Forest Management Act of 1976 (1)
recognized wilderness as a use of the forests and (2) modified the
Forest Service's mandate for fish and wildlife to require the
maintenance of diverse plant and animal communities (biological
diversity).  Similarly, the Federal Land Policy Management Act of
1976 requires the Bureau of Land Management to manage its lands for
multiple uses and sustained yield.  The act defines multiple uses to
include recreation; range; timber; minerals; watershed; fish and
wildlife and their habitat; and natural, scenic, scientific, and
historic values. 

Both the Forest Service and the Bureau of Land Management have
legislatively based incentives for producing resource commodities. 
For example, the Forest Service receives some of its operating funds
from the receipts of timber sales under the Knutson-Vandenberg Act of
1930, which authorizes the national forests to retain a portion of
their timber sale receipts to help fund reforestation and other
activities as well as regional office and headquarters expenses. 
Under the Taylor Grazing Act of 1934, the Bureau of Land Management
may issue permits for the use of rangelands only to persons engaged
in the business of livestock grazing.  The permits may not be issued
for other uses, such as to provide habitat for fish and wildlife.  As
a result, the Forest Service and the Bureau of Land Management have
managed their lands to a great extent for commodity uses, such as
timber harvesting, livestock grazing, and mineral production. 

In addition, all four agencies 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 the agencies' management of lands
and resources.  In managing their lands and resources, the agencies
must also comply with the requirements of other environmental
statutes, including the Endangered Species Act, the Clean Water Act,
and the Clean Air Act, as well as numerous other laws and
regulations.  The Forest Service alone is subject to 212 laws
affecting its activities and programs.  Authority for implementing
and enforcing these laws is dispersed among several federal agencies,
including the Fish and Wildlife Service, the Department of Commerce's
National Marine Fisheries Service, the Environmental Protection
Agency (EPA), and the U.S.  Army Corps of Engineers, as well as state
and local agencies. 


   BASIS FOR REEXAMINING FEDERAL
   PROCESSES AND STRUCTURES
---------------------------------------------------------- Chapter 0:2

Several changes and developments suggest a basis for reviewing the
current approach to federal land management with an eye to improving
its efficiency and effectiveness.  These changes and developments
include the increased similarity in the responsibilities and the
increased complexity in the management of federal lands, together
with budgetary and ecological considerations. 


      SIMILARITIES IN
      RESPONSIBILITIES
-------------------------------------------------------- Chapter 0:2.1

Over time, the responsibilities of the four major federal land
management agencies have grown more similar.  Specifically, the
Forest Service and the Bureau of Land Management now provide more
noncommodity uses on their lands.  For instance, in 1964, less than 3
percent (16 million acres) of their lands were managed for
conservation--as wilderness, wild and scenic rivers, and recreation. 
By 1994, this figure had increased to about 24 percent (over 108
million acres).\2

According to Forest Service officials, several factors have required
the agency to assume increased responsibilities for noncommodity
uses, especially for biological diversity and recreation.  These
factors include (1) the interaction of legislation, regulation, case
law, and administrative direction, (2) growing demands for
noncommodity uses on Forest Service lands, and (3) activities
occurring outside the national forests, such as timber harvesting on
state, industrial, and private lands. 

With this shift in its responsibilities, the Forest Service is less
able to meet the demands for commodity uses on its lands, especially
for timber harvesting.  For example, 77 percent of the 24.5 million
acres of Forest Service and Bureau of Land Management lands in
western Washington State, Oregon, and California that were available
for commercial timber harvesting have been set aside or withdrawn
primarily for noncommodity uses.  In addition, although the remaining
5.5 million acres, or 22 percent, are available for regulated
harvesting, the minimum requirements for maintaining biological
diversity and water quality 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.  The volume of 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.\3

While our work at the Bureau of Land Management has been more
limited, this agency is also assuming increased responsibilities for
noncommodity uses.  This shift in responsibilities of the Forest
Service and the Bureau of Land Management to more noncommodity uses
has contributed to what is sometimes referred to as a "blurring of
the lines" among the four major federal land management agencies. 


--------------------
\2 See footnote 1. 

\3 Forest Service:  Issues Related to Managing National Forests for
Multiple Uses (GAO/T-RCED-96-111, Mar.  26, 1996). 


      COMPLEXITIES WITHIN THE
      CURRENT STATUTORY FRAMEWORK
-------------------------------------------------------- Chapter 0:2.2

Some Forest Service officials are concerned about the workability of
the agency's current statutory framework, which they believe is
making the management of the national forests increasingly complex. 
They believe that it is sometimes difficult to reconcile differences
among laws and regulations.\4

For example, the National Forest Management Act requires the Forest
Service to maintain diverse plant and animal communities.  One
process that nature uses to produce such biological diversity is
periodic small wildfires that create a variety of habitats.  However,
until recently, a federal policy required the suppression of all
fires on federal lands.\5 As a result, there has been an accumulation
of fuels on the forests' floors.  The Forest Service now plans to
undertake prescribed burning to restore the forests' health and avoid
unnaturally catastrophic fires.  However, the minimum standards for
air quality required under the Clean Air Act may at times prohibit
the Forest Service from achieving this goal by limiting the timing,
location, and amount of prescribed burning that can occur.\6 In
addition, the minimum standards for water quality required under the
Clean Water Act and the conservation of species listed as endangered
or threatened under the Endangered Species Act also can limit the
timing, location, and amount of prescribed burning that can occur,
since soils from burned areas wash into streams, modifying species'
habitats. 

Reconciling differences among laws and regulations is further
complicated by the dispersal of authority for these laws among
several federal agencies and state and local agencies.  Disagreements
among the agencies on whether or how these requirements can best be
met sometimes delay projects and activities.  According to officials
in the federal land management and regulatory agencies with whom we
spoke, these disagreements often stem from differing evaluations of
environmental impacts and risks.\7 For example, in 1995, the Fish and
Wildlife Service, the National Marine Fisheries Service, and EPA
could not agree with the Forest Service on the extent of risk the
Thunderbolt salvage timber sale--on the Boise and Payette National
Forests in central Idaho--may have to salmon spawning habitat. 


--------------------
\4 Forest Service:  Issues Relating to Its Decisionmaking Process
(GAO/T-RCED-96-66, Jan.  25, 1996). 

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

\6 Forest Health:  Overview, Congressional Research Service (95-548
ENR, Apr.  28, 1995). 

\7 See footnotes 3 and 4. 


      BUDGETARY AND ECOLOGICAL
      CONSIDERATIONS
-------------------------------------------------------- Chapter 0:2.3

The federal government's increased emphasis on downsizing and
budgetary constraint demands that federal agencies look beyond
existing jurisdictional boundaries to find ways to reduce costs,
increase efficiency, and improve service to the public.  Such gains
could be achieved by refocusing, combining, or eliminating certain
functions, systems, programs, activities, or field locations.  Joint
efforts in planning and budgeting; joint use of administrative,
technical, and management systems; and joint stewardship of natural
and cultural resources could lead to greater efficiency.\8

For instance, in 1985 the Forest Service and the Bureau of Land
Management proposed to the Congress to merge all field offices
located in the same communities in western Oregon, restructure
boundaries to achieve the optimum size and balance among land units,
and eliminate some managerial and overhead positions.  The agencies
projected that this proposal would have reduced the number of
permanent employees by 280 and would have achieved annual savings of
$10.3 million (in 1985 dollars) once it was fully implemented.  The
Congress did not act on this "interchange" proposal.\9

Ecological considerations also suggest that the federal land
management agencies rethink their organizational structures and
relationships with one another.  Scientific research has increased
the agencies' understanding of the importance and functioning of
natural systems, such as watersheds, airsheds, soils, and vegetative
and animal communities, specific components of which (e.g.,
threatened and endangered species and wetlands) are protected under
various environmental statutes.  The boundaries of these natural
systems are often not consistent with existing jurisdictional and
administrative boundaries.  Hence, activities and uses affecting
these systems may need to be coordinated and managed across federal
land units and agencies.\10 For example, federal efforts to restore
the environment of South Florida--including the Everglades and
Florida Bay--transcend existing jurisdictional and administrative
boundaries and involve numerous federal agencies, including the
National Park Service, the Fish and Wildlife Service, the National
Marine Fisheries Service, EPA, and the Corps of Engineers.\11


--------------------
\8 National Park Service:  Better Management and Broader
Restructuring Efforts Are Needed (GAO/T-RCED-95-101, Feb.  9, 1995). 

\9 Forestry Functions:  Unresolved Issues Affect Forest Service and
BLM Organizations in Western Oregon (GAO/RCED-94-124, May 17, 1994). 

\10 Ecosystem Management:  Additional Actions Needed to Adequately
Test a Promising Approach (GAO/RCED-94-111, Aug.  16, 1994). 

\11 Restoring the Everglades:  Public Participation in Federal
Efforts (GAO/RCED-96-5, Oct.  24, 1995). 


   STRATEGIES FOR IMPROVING
   FEDERAL LAND MANAGEMENT
---------------------------------------------------------- Chapter 0:3

Two basic strategies have been proposed to improve federal land
management:  (1) streamlining the existing structure by coordinating
and integrating functions, systems, activities, programs, and field
locations and (2) reorganizing the structure by combining agencies. 
The two strategies are not mutually exclusive, and some prior
proposals have encompassed both. 


      STREAMLINING THE EXISTING
      ORGANIZATIONAL STRUCTURE
-------------------------------------------------------- Chapter 0:3.1

In 1983, President Reagan's Private Sector Survey on Cost Control,
also known as the Grace Commission, recommended that the Forest
Service and the Bureau of Land Management combine administrative
functions, eliminate duplicative efforts, and plan a program of
jurisdictional land transfers to accomplish these objectives.\12
Similarly, in 1993, the Clinton administration established the
Interagency Ecosystem Management Task Force to develop an approach to
ensuring a sustainable economy and a sustainable environment.  In a
November 1995 report, the task force stated that such an approach
would entail a shift from the federal government's traditional focus
on an individual agency's jurisdiction to a broader focus on the
actions of multiple agencies across larger ecological areas.  The
task force recommended that federal agencies strive for greater
flexibility in pursuing their missions within existing legal
authorities and develop better information, communication,
coordination, and partnerships.\13 In December 1995, 13 federal
departments and agencies, together with the Council on Environmental
Quality, signed a memorandum of understanding establishing a network
of agency coordinators and pledging to work together in support of
such an approach. 

On February 1, 1994, and February 9, 1995, we testified that the four
major federal land management agencies need to reduce costs, increase
efficiency, and improve service to the public, as well as manage
activities and uses across existing federal land units and
jurisdictions so as to preserve the nation's natural resources and
sustain their long-term economic productivity.  This approach would
require them to look beyond their jurisdictions and work with the
Congress and each other to develop a strategy to coordinate and
integrate their functions, systems, activities, and programs so that
they can operate as a unit at the local level.\14

Over the last several years, the Forest Service and the Bureau of
Land Management have collocated some offices or shared space with
other federal agencies.  They have also pursued other means of
streamlining, sharing resources, and saving rental costs.  However,
the four major federal land management agencies have not, to date,
developed a strategy to coordinate and integrate their functions,
systems, activities, and programs. 


--------------------
\12 Report of the President's Private Sector Survey on Cost Control
(Washington D.C.:  Aug.  1983). 

\13 The Ecosystem Approach:  Healthy Ecosystems and Sustainable
Economies, Volume II - Implementation Issues, Report of the
Interagency Ecosystem Management Task Force (Nov.  1995). 

\14 See footnote 8 and Forest Service Management:  Issues to Be
Considered in Developing a New Stewardship Strategy
(GAO/T-RCED-94-116, Feb.  1, 1994). 


      REORGANIZING THE STRUCTURE
      OF FEDERAL LAND MANAGEMENT
-------------------------------------------------------- Chapter 0:3.2

Several proposals for improving federal land management would
reorganize the existing structure by combining various agencies.  For
example, in its 1970 report to the President and the Congress, the
Public Land Law Review Commission (a bipartisan group established by
the Congress in 1964 with members appointed by both the President and
the Congress) recommended that the Forest Service be transferred from
the Department of Agriculture to the Department of the Interior,
which would then be renamed the Department of Natural Resources.\15
Subsequent proposals included additional agencies.  For example, in
1971-72, the Nixon administration proposed adding the Corps of
Engineers, Agriculture's Soil Conservation Service (now the Natural
Resources Conservation Service), and the National Oceanographic and
Atmospheric Administration in the Department of Commerce (which
includes the National Marine Fisheries Service).\16 Eight years
later, the Carter administration made a similar proposal.\17

Some Forest Service officials, including the Chief, believe that a
commission similar to the Public Land Law Review Commission may need
to be established if federal land management is to be improved.  Such
a commission would need to conduct a thorough review of federal land
management and report its findings to the President and the Congress. 


--------------------
\15 One Third of the Nation's Land:  A Report to the President and to
the Congress by the Public Land Law Review Commission (Washington
D.C.:  June 1970). 

\16 Papers Relating to the President's Departmental Reorganization
Program:  A Reference Compilation (Washington D.C.:  Feb.  1972). 

\17 President's Reorganization Project:  Report on the Reorganization
Study of Natural Resource Functions, Office of Management and Budget
(Washington D.C.:  June 1979). 


   PRINCIPLES TO BE CONSIDERED IN
   STREAMLINING OR REORGANIZING
   FEDERAL LAND MANAGEMENT
---------------------------------------------------------- Chapter 0:4

Despite the commissions, reports, and recommendations over the past
26 years for streamlining or reorganizing federal land management, no
significant legislation has been enacted.  These efforts have not
succeeded, in part, because they have not been supported by a solid
consensus for change.  For example, the Carter administration
estimated that its proposal to create a Department of Natural
Resources would result in annual savings of up to $100 million. 
However, it did not specify how these savings would be
accomplished,\18 and a consensus for change was never achieved. 

On May 17, 1995, in testimony before this Committee, the Comptroller
General identified five principles to consider during any effort to
streamline or reorganize government.  These principles are based on
past governmental restructuring efforts--both inside and outside the
United States.\19

  -- Reorganization demands a coordinated approach, within and across
     agency lines, supported by a solid consensus for change in both
     the Congress and the administration. 

  -- Reorganization should seek to achieve specific, identifiable
     goals. 

  -- Once goals are defined, attention must be paid to how the
     federal government exercises its role--both in terms of
     organization and tools. 

  -- Effective implementation is critical to success. 

  -- Sustained oversight by the Congress is needed to ensure
     effective implementation. 

Because the federal land management agencies have similar
responsibilities yet different legislative requirements, any effort
to streamline or reorganize them will require a coordinated approach
within and across the agencies to avoid creating new, unintended
consequences for the future.  In particular, potential gains in
efficiency need to be balanced against the policy reasons that led to
the existing structure.  For example, transferring responsibility for
environmental compliance from regulatory agencies, such as the Fish
and Wildlife Service, EPA, and the Corps of Engineers, to the Forest
Service and the Bureau of Land Management may help expedite the
implementation of projects and activities.  However, any potential
gains in efficiency from such a transfer would need to be balanced
against the policy reasons that led originally to separating the
responsibility for federal land management from the responsibility
for regulatory compliance. 

Moreover, while there may be a growing consensus for streamlining or
reorganizing the existing structure of federal land management, as
the Comptroller General noted in his May 17, 1995, testimony, the key
to any streamlining or reorganization plan--and the key to building a
consensus behind it--is the creation of specific, identifiable goals. 
Applying this principle to federal land management will require
decisionmakers to agree on, among other issues, how to balance
differing objectives for commodity and noncommodity uses over the
short and long term. 

For example, the Forest Service is experiencing increasing difficulty
in reconciling conflicts among competing uses on its lands, and
demands for forest uses will likely increase substantially in the
future.\20 Some Forest Service officials believe that the laws
governing the agency's mission provide little guidance for resolving
these conflicts.\21 As a result, they have suggested that the
Congress needs to provide greater guidance on how the agency is to
balance competing uses and ensure their sustainability.  In
particular, the Chief of the Forest Service 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
need to be acknowledged.\22

Once decisionmakers reach a consensus on specific, identifiable
goals, the desired results these goals are to accomplish should be
made explicit through performance measures.  The Congress, in
enacting the Government Performance and Results Act of 1993,
recognized that to be effective, goals need measures to assess
results.  Without such measures, the agencies' ability to improve
performance and the Congress's ability to conduct effective oversight
will be hampered. 

Moreover, goals cannot be set and performance measures cannot be
defined in a vacuum.  Decisionmakers need to consider how the desired
goals will be achieved.  Our past work on reorganizations has shown
that, all too often, the issue of how desired goals are to be
achieved is not considered as part of the goal-setting process. 
Considering such issues as how agencies' structures and processes
will need to function to accomplish the goals can benefit the
goal-setting process itself.  By thinking through the implementation
process, decisionmakers are better able to clarify the goals and the
results to be achieved and to identify potential pitfalls. 


--------------------
\18 The Forest Service and the Bureau of Land Management:  History
and Analysis of Merger Proposals, Congressional Research Service
(95-1117 ENR, Washington D.C.:  Nov.  7, 1995). 

\19 Government Reorganization:  Issues and Principles
(GAO/T-GGD/AIMD-95-166, May 17, 1995). 

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

\21 See footnote 4. 

\22 See footnote 3. 


-------------------------------------------------------- Chapter 0:4.1

In summary, Mr.  Chairman, the responsibilities of the four major
federal land management agencies have become more similar and the
management of federal lands more complex over time.  These changes,
as well as budgetary and ecological considerations, suggest a basis
for reexamining the current approach to federal land management with
an eye to improving its efficiency and effectiveness.  Two basic
strategies have been proposed to improve federal land management--one
would focus primarily on streamlining the existing structure by
coordinating and integrating functions, systems, activities,
programs, and field locations, while the other would reorganize the
structure primarily by combining agencies.  Although it is not clear
which strategy would be more effective, or whether a combination of
the two would be more appropriate, it is clear that the effective
implementation of either strategy will require, among other things, a
solid consensus for change and the creation of specific, identifiable
goals for managing commodity and noncommodity uses. 

Mr.  Chairman, this concludes my prepared statement.  We will be
pleased to answer any questions that you or Members of the Committee
may have. 


*** End of document. ***