Tongass National Forest: Lack of Accountability for Time and Costs Has
Delayed Forest Plan Revision (Testimony, 04/29/97, GAO/T-RCED-97-153).

GAO discussed the decisionmaking process being used by the Forest
Service to revise the land management plan for the Tongass National
Forest in southeastern Alaska.

GAO noted that its work on the Forest Service's process for revising the
Tongass forest plan showed that: (1) the Service originally planned to
spend 3 years revising the plan; (2) at the end of 3 years, the agency
had spent about $4 million; however, it has spent another 7 years and $9
million studying and restudying issues without establishing a clear
sequence or schedule for their timely resolution, attempting to
reconcile its older emphasis on producing timber with its more recent
emphasis on sustaining wildlife and fish, and attempting to reach
agreement with federal regulatory agencies on an acceptable level of
risk to individual natural resources; (3) GAO's work identified that
these factors have contributed to inefficiency in decisionmaking
throughout the agency; (4) in revising the Tongass forest plan, the
Service has incurred unexpected delays and high costs to better ensure
that the new plan is legally defensible, scientifically credible, and
able to sustain the forest's resources;(5) developing a forest plan to
avoid or prevail against legal challenges has become increasingly
time-consuming and costly; (6) on the Tongass, insufficient data and
scientific uncertainty have hindered the development of a plan that can
ensure the maintenance of viable populations of animals; (7) as an
option to further study and planning without resolution, the Service may
be able to move forward with a decision conditioned on an adequate
monitoring component and modify the decision when new information is
uncovered or when preexisting monitoring thresholds are crossed; (8)
however, the Service has historically failed to live up to its own
monitoring requirements and, as a result, federal regulatory agencies
and other stakeholders continue to insist that the Service prepare
increasingly time-consuming and costly detailed environmental analyses
and documentation before making a decision, effectively front-loading
the process and perpetuating the cycle of inefficiency; (9) while the
agency is being held accountable for developing a plan that may be
legally defensible, scientifically credible, and able to sustain the
forest's resources, it is not being held accountable for making a
timely, orderly, and cost-effective decision; and (10) the costs of the
Service's indecision in revising the Tongass plan are being borne by the
American taxpayer and by the members of the public who are concerned ab*

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

 REPORTNUM:  T-RCED-97-153
     TITLE:  Tongass National Forest: Lack of Accountability for Time 
             and Costs Has Delayed Forest Plan Revision
      DATE:  04/29/97
   SUBJECT:  Forest management
             Strategic planning
             National forests
             Accountability
             Environmental monitoring
             Environment evaluation
             Wildlife conservation
             Land use law
             Interagency relations
             Endangered animals
IDENTIFIER:  Alaska
             Tongass National Forest (AK)
             Forest Service Tongass Land Management Plan
             Alexander Archipelago Wolf
             Queen Charlotte Goshawk
             
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Cover
================================================================ COVER


Before the Committee on Energy and Natural Resources, U.  S.  Senate

For Release
on Delivery
Expected at
10:00 a.m.  EDT
Tuesday
April 29, 1997

TONGASS NATIONAL FOREST - LACK OF
ACCOUNTABILITY FOR TIME AND COSTS
HAS DELAYED FOREST PLAN REVISION

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

GAO/T-RCED-97-153

GAO/RCED-97-153T


(140111)


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

  EPA -
  USDA -
  NEPA -
  NFMA -
  ANILCA -

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

Mr.  Chairman and Members of the Committee: 

We are pleased to be here today to discuss the decision-making
process being used by the Department of Agriculture's Forest Service
to revise the land management plan for the Tongass National Forest in
southeastern Alaska.\1 As requested, we will compare the results of
our work for you and Chairmen Stevens and Young on the agency's
process for revising the Tongass forest plan with the findings in the
report\2 we are issuing today to you and other requesters on the
causes of inefficiency and ineffectiveness throughout the Forest
Service's decision-making process. 

Our work on the Forest Service's process for revising the Tongass
forest plan showed the following: 

  -- The Forest Service originally planned to spend 3 years revising
     the plan.  At the end of 3 years, the agency had spent about $4
     million.  However, the Forest Service has spent another 7 years
     and $9 million\3 (1) studying and restudying issues without
     establishing a clear sequence or schedule for their timely
     resolution; (2) attempting to reconcile its older emphasis on
     producing timber with its more recent emphasis on sustaining
     wildlife and fish; and (3) attempting to reach agreement with
     federal regulatory agencies on an acceptable level of risk to
     individual natural resources, such as endangered and threatened
     species, water, and air.  Our Forest Service-wide work
     identified that these factors have contributed to inefficiency
     in decision-making throughout the agency. 

  -- In revising the Tongass forest plan, the Forest Service has
     incurred unexpected delays and high costs to better ensure that
     the new plan is legally defensible, scientifically credible, and
     able to sustain the forest's resources.  Here, as elsewhere,
     developing a forest plan to avoid or prevail against legal
     challenges has become increasingly time-consuming and costly. 
     On the Tongass, insufficient data and scientific uncertainty
     have hindered the development of a plan that can ensure the
     maintenance of viable populations of animals.  As an option to
     further study and planning without resolution, the Forest
     Service may be able to move forward with a decision conditioned
     on an adequate monitoring component and modify the decision when
     new information is uncovered or when preexisting monitoring
     thresholds are crossed.  However, as our report states, the
     Forest Service has historically failed to live up to its own
     monitoring requirements.  As a result, federal regulatory
     agencies and other stakeholders continue to insist that the
     Forest Service prepare increasingly time-consuming and costly
     detailed environmental analyses and documentation before making
     a decision--effectively front-loading the process and
     perpetuating the cycle of inefficiency. 

  -- While the agency is being held accountable for developing a plan
     that may be legally defensible, scientifically credible, and
     able to sustain the forest's resources, it is not being held
     accountable for making a timely, orderly, and cost-effective
     decision.  Accountability fixes responsibility and implies a
     consequence for making--or, in the case of revising the Tongass
     plan, not making--a certain decision.  However, the costs of the
     Forest Service's indecision in revising the Tongass plan are
     being borne, not by the decisionmakers, but rather by the
     American taxpayer and by the members of the public who are
     concerned about maintaining the forest's diverse species but are
     precluded from forming reasonable expectations about the
     forest's health over time and/or are economically dependent on
     the Tongass but are uncertain about the future availability of
     its uses. 

Mr.  Chairman, our report identifies a framework for breaking the
cycle of inefficiency by improving the Forest Service's
decision-making.  In particular, we believe that the Government
Performance and Results Act of 1993, if implemented successfully,
will strengthen accountability for performance and results within the
Forest Service and improve the efficiency and effectiveness of its
decision-making. 


--------------------
\1 The process used by the Forest Service to revise the Tongass land
management plan is discussed in detail in app.  I. 

\2 Forest Service Decision-Making:  A Framework for Improving
Performance (GAO/RCED-97-71, Apr.  29, 1997). 

\3 The Forest Service's costs to revise the Tongass plan are detailed
in app.  II. 


   DELAYS AND INCREASED COSTS IN
   REVISING THE TONGASS PLAN CAN
   BE TRACED PRIMARILY TO THREE
   FACTORS
---------------------------------------------------------- Chapter 0:1

Among its findings, our report notes that inefficiency in the Forest
Service's decision-making process can result when (1) the agency
identifies issues but then conducts continual and/or multiple studies
to address them without establishing any clear sequence for their
timely resolution; (2) stakeholders, both inside and outside the
agency, cannot agree on how the Forest Service is to resolve
conflicts among competing uses on its lands and needed improvements
are delayed; and (3) the Forest Service and federal regulatory
agencies cannot agree on an acceptable level of risk to endangered
and threatened species, water, air, and other individual natural
resources.  The Forest Service's process for revising the Tongass
forest plan illustrates how each of these factors affects the
efficiency of the agency's decision-making. 


      ISSUES HAVE BEEN IDENTIFIED
      BUT NOT RESOLVED
-------------------------------------------------------- Chapter 0:1.1

On the Tongass, as elsewhere, the Forest Service tends to study and
restudy issues without reaching closure.  For example, a scoping
process begun in 1987 identified wildlife and fish habitats as two
issues needing special attention in revising the Tongass plan.  The
Forest Service team revising the plan established a committee--the
"viable population" committee--to study the viability of various
old-growth-dependent species.  In 1992, this committee produced a
draft strategy for preserving wildlife, which was reviewed
twice--first by a wildlife ecologist from the Forest Service's
Pacific Northwest Research Station (a research arm of the agency) and
later in a report by the research station, which contained 18
individual scientific reviews and a legal review.  Also in 1992, the
Forest Service team revising the plan performed its own study of the
viability of wildlife and fish.  This study, which included an
examination of the viable population committee's strategy, was also
reviewed by the research station. 

In 1994, a new regional forester expanded the team revising the plan
by adding research scientists from the research station and tasked
them with gathering information on five issues, including wildlife
viability.  The agency then convened six panels of experts and
scientists to assess the risk each of the nine alternatives presented
in a third draft of a revised Tongass plan could pose to particular
species of wildlife.  Three more panels were convened to assess the
potential risks posed by these alternatives to terrestrial mammals,
fish and riparian areas, and old-growth forests.  In March 1997, the
Forest Service reconvened the panels to assess (1) the alternatives,
some of which had been modified since the third draft was released
for public comment in April 1996, and (2) the potential risks to
certain species of fish and wildlife posed by a new preferred
alternative.  Today, the issue of wildlife viability has still not
been resolved. 


      AGREEMENT ON WHICH USES TO
      EMPHASIZE HAS BEEN DIFFICULT
      TO REACH
-------------------------------------------------------- Chapter 0:1.2

The Forest Service also has had difficulty reconciling its older
emphasis on producing timber with its more recent emphasis on
sustaining wildlife and fish under its broad multiple-use and
sustained-yield mandate.  Resolving disagreements over this issue
within the agency delayed the Tongass forest plan's revision. 

Our report shows that during the last 10 years, the Forest Service
has increasingly shifted the emphasis under its broad multiple-use
and sustained-yield mandate from consumption (primarily producing
timber) to conservation (primarily sustaining wildlife and fish). 
This shift is taking place in reaction to requirements in planning
and environmental laws and their judicial interpretations--reflecting
changing public values and concerns--together with social,
ecological, and other factors.  The increasing emphasis on sustaining
wildlife and fish sometimes conflicts with the agency's older
emphasis on producing timber and underlies the Forest Service's
inability to achieve the goals and objectives for timber production
in many of the first forest plans, including the 1979 Tongass plan. 

When the Forest Service began to revise the Tongass plan in 1987, it
was just beginning, as an agency, to shift its emphasis from
producing timber to sustaining wildlife and fish.  This shift has not
been smooth and has contributed significantly to the delays and costs
incurred in revising the plan. 

For example, 3 years after the Forest Service began to revise the
Tongass forest plan, the Congress enacted the Tongass Timber Reform
Act of 1990.  Among its provisions, the act (1) eliminated a special
funding provision in a 1980 act (the Alaska National Interests Lands
Conservation Act) intended to maintain the timber supply from the
Tongass to the dependent industry; (2) directed the agency to
maintain buffers of standing timber between designated streams and
timber harvest areas to protect fish and wildlife habitat, such as
spawning ground for salmon; (3) designated additional wilderness
areas within the forest; and (4) designated 12 additional special
management areas in which harvesting timber and building roads are
generally prohibited.  The 1990 act also unilaterally made nine
modifications to long-term timber sale contracts held by two
companies--the Alaska Pulp Corporation and the Ketchikan Pulp
Company--that harvested large amounts of timber in the forest.  Among
other things, the act modified the contracts to eliminate
disproportionately high harvests of old-growth timber.\4

Other events reflecting the Forest Service's increasing emphasis on
sustaining wildlife and fish also delayed the agency's revision of
the Tongass forest plan.  For example, in a 1988 decision on an
appeal of the approved forest plan for the Flathead National Forest
in northwestern Montana, the Associate Chief of the Forest Service
directed the regional forester to leave 10 percent of certain
watersheds in old-growth areas large enough to provide habitat for
certain species until the regional forester completed additional
analyses of these species' habitat requirements.  In 1990, an
interagency scientific committee--established to develop a strategy
for conserving the northern spotted owl in the Pacific
Northwest--also advocated the retention of large blocks of old-growth
forests to ensure the viability of populations of
old-growth-dependent species.  Finally, in 1992, the Chief of the
Forest Service announced plans to reduce the amount of timber
harvested by clearcutting by as much as 70 percent from fiscal year
1988 levels.  Forest Service officials revising the Tongass forest
plan believed that this new information and these events could have a
significant impact on managing a forest that, up until then, had
relied primarily on even-age management (clearcutting).  These
officials therefore believed that the new information and events
needed to be considered in finalizing the revised forest plan.  By
this time, the process to revise the Tongass forest plan had entered
its fifth year. 

The Forest Service's response to this new information and these
events was slowed, however, by internal disagreements concerning
which use--producing timber or sustaining wildlife and fish--should
be emphasized and how the forest should resolve conflicts or make
choices between these competing uses on its lands.  For example, the
Forest Service team revising the forest plan disagreed with the
viable population committee's proposed strategy for preserving
certain species of wildlife on the forest.  The committee's proposed
strategy would have given more emphasis to sustaining wildlife than
the team's preferred alternative.  In our view, this disagreement
permeated other decision-making levels as well, extending to the
forest supervisors and regional foresters.  The friction on the
Tongass over mission priorities is characteristic of an agency in
transition and mirrors conflicts within the Forest Service as a
whole--some Forest Service personnel support the agency's shift in
emphasis while others continue to believe that timber should receive
the same priority it did in the past. 


--------------------
\4 Tongass National Forest:  Contractual Modification Requirements of
the Tongass Timber Reform Act (GAO/RCED-91-133, Mar.  28, 1991) and
Tongass Timber Reform Act:  Implementation of the Act's Contract
Modification Requirements (GAO/RCED-95-2, Jan.  31, 1995). 


      DISAGREEMENTS WITH FEDERAL
      REGULATORY AGENCIES HAVE
      ALSO DELAYED THE APPROVAL OF
      A REVISED TONGASS FOREST
      PLAN
-------------------------------------------------------- Chapter 0:1.3

Our report on the Forest Service's decision-making process states
that interagency disagreements have delayed forest plans and
projects.  Disagreements between the Forest Service and federal
regulatory agencies--including Interior's Fish and Wildlife Service,
Commerce's National Marine Fisheries Service, and the Environmental
Protection Agency (EPA)--over the best approaches to achieving
environmental objectives and implementing laws and regulations often
stem from the agencies' differing evaluations of environmental
effects and risks, which in turn reflect the agencies' disparate
missions and responsibilities.  We found that such disagreements had
delayed planning for the Tongass. 

The Forest Service's April 1996 draft plan and preferred alternative
represent the intermediate results of almost 9 years of planning. 
Not only the preferred alternative for managing the Tongass, selected
by the forest's three supervisors, but also the majority of the other
nine alternatives presented in the April 1996 draft plan would
increase the forest's emphasis on sustaining wildlife and fish and
decrease the annual timber-offering goal, compared with the current
plan.  According to the forest supervisors, the preferred alternative
is consistent with the Forest Service's broad multiple-use and
sustained-yield mandate. 

However, according to the federal regulatory agencies that are
charged with implementing and enforcing environmental laws and
regulations--including those to conserve and protect individual
natural resources, such as endangered and threatened species, water,
and air--the preferred alternative poses a high level of risk to
wildlife and their habitat.  Even though the Forest Service
established an interagency policy group in mid-1994, which included
program managers from the three regulatory agencies, to advise the
team revising the Tongass forest plan, all three regulatory agencies
criticized the April 1996 preferred alternative and suggested changes
to reduce the level of risk to wildlife and their habitat. 

In particular, the Fish and Wildlife Service was concerned about the
preferred alternative's guidelines for habitat management as they
apply to old-growth-dependent species on the Tongass, including two
species that have been proposed for listing under the Endangered
Species Act (the Alexander Archipelago wolf and the Queen Charlotte
goshawk).  If these species are listed after a revised forest plan is
approved, the Forest Service could be required to reinitiate formal
consultations with the Fish and Wildlife Service to again amend or
revise the plan.  This interagency disagreement has further delayed
the approval of a revised Tongass forest plan. 


   UNDERLYING ISSUES CONTRIBUTE TO
   INEFFICIENCY
---------------------------------------------------------- Chapter 0:2

In the end, the Forest Service hopes to approve a revised Tongass
plan that is legally defensible, scientifically credible, and able to
sustain the forest's resources.  However, as its experience in
revising the Tongass forest plan has shown, developing a forest plan
to avoid or prevail against legal challenges has become increasingly
costly and time-consuming.  On the Tongass, insufficient data and
scientific uncertainty have hampered the development of a plan that
can ensure the maintenance of viable populations of wildlife.  As an
option to move beyond inclusive studies, the Forest Service may be
able to move forward with a decision conditioned on an adequate
monitoring component.  However, the Forest Service has historically
failed to live up to its own monitoring requirements, and federal
regulatory agencies and other stakeholders continue to insist that
the Forest Service front-load the process.  This preparation of
increasingly time-consuming and costly detailed environmental
analyses and documentation before making a decision has helped
perpetuate the cycle of inefficiency. 


      DEVELOPING A LEGALLY
      DEFENSIBLE PLAN IS COSTLY
      AND TIME-CONSUMING
-------------------------------------------------------- Chapter 0:2.1

In a March 10, 1997, letter to you, Mr.  Chairman, the Secretary of
Agriculture stated that the Forest Service is completing a final
legal review of its most recent preferred alternative to revising the
Tongass plan to ensure that it is legally defensible.  In our report,
we state that, according to the Forest Service, it spends more than
$250 million a year conducting extensive, complex environmental
analyses and preparing environmental documents in order to comply
with the requirements of the National Environmental Policy Act and
other environmental laws and to avoid or prevail against challenges
to its compliance with these laws. 

In 1995, the Forest Service reported that it prepared about 20,000
environmental documents annually--more than any other federal agency. 
In 1994 (the last year for which data are available) the agency
issued almost 20 percent of all the final environmental impact
statements prepared by federal agencies (50 out of a total of 253). 

According to an internal Forest Service report, conducting
environmental analyses and preparing environmental documents consumes
about 18 percent of the funds available to manage the national
forests and approximately 30 percent of the agency's field resources. 
Preparing timber sales on the basis of an approved forest plan
usually takes another 3 to 8 years. 

In March 1989, the Forest Service initiated a comprehensive review of
its land management process and completed a critique in May 1990.  On
the basis of the critique, the agency proposed revisions to its
planning regulations\5 in April 1995.  These revisions were intended
to, among other things, clarify the nature of forest plan decisions
and define the appropriate scope of environmental analyses.  After 2
years, the Forest Service has still not finalized these revisions. 


--------------------
\5 60 Fed.  Reg.  18886 (Apr.  13, 1995). 


      THE FOREST SERVICE'S
      VIABILITY REQUIREMENT MAY
      NOT BE MET
-------------------------------------------------------- Chapter 0:2.2

In his March 10th letter to you, the Secretary of Agriculture also
stated that the Forest Service is completing a final substantive
review of its most recent preferred alternative to revising the
Tongass plan to ensure that it is scientifically credible and will
sustain the resources of the forest.  Toward this end, the Forest
Service has devoted substantial resources and time to ensure that the
revised forest plan meets a requirement in its regulations relating
to maintaining the diversity of animal communities.  However, the
Forest Service has asserted that this requirement, if interpreted
literally, envisions an outcome that is sometimes impossible to be
guaranteed by any agency, regardless of the analytical resources
marshalled. 

The Forest Service's biological diversity requirement for fish and
wildlife habitat--found in its regulations implementing the National
Forest Management Act of 1976--requires the agency to maintain
well-distributed viable populations of existing native and desired
non-native vertebrate species in the planning area.  However, in the
revisions proposed to its planning regulations in April 1995, the
Forest Service states that the scientific expertise, data, and
technology currently needed to conduct the required assessments of
species' viability far exceed the resources envisioned by the agency
when the planning rule was developed, as well as the resources
available to any agency or scientific institution.  Therefore,
according to the Forest Service, the viable populations requirement
no longer meets its expectations. 

The proposed revisions include an option for sustaining diversity
preferred by the Forest Service.  This option would protect the
habitats of most species and use the Endangered Species Act as a
"fine filter" to catch and support the special needs of species that
otherwise would go unmet.  However, since the Forest Service has not
finalized the proposed revisions to its planning regulations, the
revised Tongass forest plan must satisfy a requirement that the
agency asserts is sometimes impossible to meet. 


      THE FOREST SERVICE HAS NOT
      ADEQUATELY MONITORED THE
      EFFECTS OF ITS DECISIONS
-------------------------------------------------------- Chapter 0:2.3

An option to avoid the growing delays and increasing costs incurred
in attempting to ensure that a decision is scientifically credible
and legally defensible may be for the Forest Service to move forward
with a decision using the best information available.  According to
an interagency task force chaired by the Council on Environmental
Quality, an agency can condition a decision--the effects of which may
be difficult to determine in advance because of uncertainty or
costs--on the monitoring of uncertainties, indicate how the decision
will be modified when new information is uncovered or when
preexisting monitoring thresholds are crossed, and reexamine the
decision in light of its results or when a threshold is crossed. 

However, the Forest Service (1) has historically given a low priority
to monitoring, (2) continues to approve projects without an adequate
monitoring component, and (3) has not generally monitored the
implementation of forest plans as required by its current
regulations.  As a result, federal regulatory agencies and other
stakeholders will likely continue to insist that the Forest Service
prepare detailed environmental analyses and documentation--which have
become increasingly costly and time-consuming--before making
decisions rather than support what many Forest Service officials
believe to be the more efficient and effective option of monitoring
and evaluation. 

Both the Fish and Wildlife Service and EPA have already expressed
reservations about the adequacy of the monitoring component in the
Forest Service's April 1996 draft Tongass plan.  In commenting on the
draft plan, the Fish and Wildlife Service stated that the proposed
standards and guidelines are too vague and will not provide for the
intended accountability because compliance will be difficult or
impossible to measure.  EPA commented that the plan did not provide
sufficient information to clearly indicate how monitoring would be
integrated into the management strategy. 


   THE FOREST SERVICE IS NOT
   ACCOUNTABLE FOR THE TIME AND
   COSTS OF ITS DECISION-MAKING
---------------------------------------------------------- Chapter 0:3

Inefficiencies within the Forest Service's decision-making process on
the Tongass and on other national forests lead to the inevitable
question--why?  Why does an agency study and restudy issues without
reaching closure?  Why does this same agency attempt to do what it
says sometimes cannot be done regardless of the time and money
invested?  And why does it spend a significant portion of its limited
resources on conducting environmental analyses and preparing
environmental documents rather than on the apparently more efficient
and effective option of monitoring the environmental effects of its
decisions? 

Although the Forest Service is held accountable for developing forest
plans that may be scientifically credible and legally defensible, it
is not held accountable for developing them in a timely, orderly, and
cost-effective manner.  The agency itself pays for the time and costs
associated with legal challenges to the scientific credibility and
legal defensibility of its decisions, but others bear the costs of
its indecision and delays.  The American taxpayer bears the financial
costs, while the costs associated with the uncertainty of not having
an approved forest plan are borne by members of the public who are
concerned about maintaining biological diversity but are precluded
from forming reasonable expectations about the forest's health over
time as well as those who are economically dependent on the Tongass
but are precluded from forming reasonable expectations about the
future availability of the forest's uses. 

Although the Forest Service has been shifting its emphasis from
consumption to conservation on the Tongass as well as nationwide, the
Tongass continues to play an important role in the economy of
southeastern Alaska, and the Forest Service retains a responsibility
under its multiple-use and sustained-yield mandate to manage the
Tongass for other uses, including timber.  While one long-term
contract was terminated and the remaining long-term contract was
recently modified to terminate no later than October 2000, the agency
has sold, and will continue to sell, timber from the forest to other
companies. 

Moreover, according to the Forest Service, many communities in
southeastern Alaska also depend on the Tongass to provide natural
resources for uses such as fishing, recreation, tourism, mining, and
customary and traditional subsistence.  However, without an approved
revised plan, the communities and companies that are economically
dependent on the Tongass for goods and services cannot form the
reasonable expectations about the future availability of forest uses
that they need to plan or to develop long-range investment
strategies. 


   THE GOVERNMENT PERFORMANCE AND
   RESULTS ACT COULD PROVIDE A
   FRAMEWORK FOR IMPROVING
   PERFORMANCE
---------------------------------------------------------- Chapter 0:4

Mr.  Chairman, the inefficiency that is occurring in the process to
revise the Tongass plan is occurring at every decision-making level
within the Forest Service.  An internal Forest Service report
estimates that inefficiencies within the agency's decision-making
process cost up to $100 million a year at the project level alone. 
Delays in finalizing forest plans, coupled with delays in finalizing
agencywide regulations and reaching individual project decisions, can
total a decade or longer. 

Our report identifies a framework for breaking the existing cycle of
inefficiency by improving the Forest Service's decision-making.  We
identify the need to provide the agency with clearer guidance on (1)
which uses it should emphasize under its broad multiple-use and
sustained-yield mandate and how it is to resolve conflicts or make
choices among competing uses on its lands and (2) how to resolve
environmental issues that transcend its administrative boundaries and
jurisdiction.  Our report also identifies the need for a systematic
and comprehensive analysis of the laws affecting the Forest Service's
decision-making to adequately address the differences in their
requirements.  We believe that the Government Performance and Results
Act of 1993, if implemented successfully, provides a framework for
addressing many of these issues and will strengthen accountability
for performance and results within the Forest Service and improve the
efficiency and effectiveness of its decision-making. 

In addition, our report identifies the need to hold the Forest
Service more accountable for its performance.  In the near future,
the Forest Service is required by the Government Performance and
Results Act to consult with you and to consider your views in
developing a strategic plan.  According to the agency, one of the
long-term strategic goals that it will discuss is ensuring
organizational effectiveness.  On the basis of our report and
hearings held during the 104th and 105th Congresses, including the
one held here today, we believe that you should expect to see (1)
performance goals and measures based on improving the efficiency and
effectiveness of the agency's decision-making process and (2)
individual performance management, career development programs, and
pay and promotion standards tied to this strategic goal. 

When accountability for the efficiency and effectiveness of
decision-making is fixed, performance and results should be improved. 
We believe that you should expect to see schedules for implementing
improvements to the decision-making process, including one to
finalize the proposed revisions to the agency's planning regulations,
as well as a plan to closely monitor progress and periodically report
on performance--both of which are needed to break the cycle of
studying and restudying issues without timely resolution. 

Forest Service managers should then seek out best practices that
could enhance efficiency and effectiveness.  In particular, they
should begin to monitor the effects of their decisions, as they are
currently required to do.  Federal regulatory agencies may then be
more willing to accept a higher level of risk to wildlife and their
habitat in forest plans then they are willing to do now. 


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

In summary, Mr.  Chairman, forest planning is, by its very nature, a
complex and difficult process involving a multitude of resources,
statutory responsibilities, and stakeholders.  Moreover, solutions to
some issues that affect the efficiency and effectiveness of the
Forest Service's decision-making will require the involvement of
other stakeholders, including the Congress and other federal
agencies.  However, we have observed a cascading series of factors
and issues resulting in inefficiencies within the Forest Service's
decision-making process that can be traced back to a lack of
accountability for time and costs.  Without being held accountable
for the efficiency of its decision-making process, the Forest Service
has allowed complexities and difficulties to become excuses for
delays and increased costs rather than challenges that must be
overcome in making timely decisions.  One result has been that the
agency has taken a reactive, rather than a proactive, approach to
addressing these challenges. 

As the Forest Service's efforts to revise the Tongass plan and its
planning regulations have shown, the most likely outcomes of the
Forest Service's current decision-making process are indecision and
delay.  We believe that successful implementation of the Government
Performance and Results Act should strengthen accountability for
performance and results within the Forest Service and improve the
efficiency and effectiveness of its decision-making.  However, as
evidenced by the agency's efforts to revise the Tongass forest plan,
sustained management attention within the Forest Service and
sustained oversight by the Congress will be required to ensure the
full and effective implementation of the act's legislative mandates. 

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


PROCESS USED TO REVISE THE TONGASS
FOREST PLAN
=========================================================== Appendix I

The U.S.  Department of Agriculture's (USDA) Forest Service has spent
almost 10 years revising a land management plan, commonly called a
forest plan, for the Tongass National Forest.  During this time, the
Alaska Region released three drafts of the plan for public comment--a
June 1990 draft, a September 1991 supplement to the draft, and an
April 1996 revision to the supplement.  As of April 1997, the Forest
Service had not approved a revised forest plan for the Tongass. 
Figure I.1 summarizes the major events in developing a revision to
the Tongass forest plan. 

   Figure I.1:  Timeline of Major
   Events in Tongass Forest Plan's
   Revision

   (See figure in printed
   edition.)


   BACKGROUND
--------------------------------------------------------- Appendix I:1

At 16.8 million acres, the Tongass is the largest forest in the
United States, roughly equal in size to West Virginia (see fig. 
I.2).  The Forest Service manages the Tongass to sustain various
multiple uses, including timber, outdoor recreation, and fish and
wildlife.  The Forest Service's Alaska Region, headquartered in
Juneau, Alaska, is responsible for managing the forest.  The Tongass
is the only national forest with more than one forest supervisor. 
Because of its size, the Tongass is divided into three administrative
areas--Chatham, Stikine, and Ketchikan--each of which has an area
office headed by a forest supervisor. 

   Figure I.2:  Tongass National
   Forest

   (See figure in printed
   edition.)

Source:  Forest Service's Alaska Region. 

Also unique to the Tongass has been its use of timber contracts valid
for up to 50 years.  In the 1950s, the Forest Service awarded three
such long-term contracts to timber companies to harvest timber in the
Tongass.  A fourth contract was awarded in the l960s but was
cancelled before operations began.  When initiated, the contracts
required that each of the companies construct and operate pulp mills
to provide steady employment in southeastern Alaska.  The companies
also used timber supplied under contracts to operate sawmills in the
region.  In return, the companies were to receive a guaranteed supply
of timber.  Federal law now generally limits the duration of timber
sale contracts to 10 years or less. 

One of the three contracts awarded in the 1950s was completed in
1982.  In April 1994, the Forest Service terminated one of the
long-term timber sale contracts, asserting that the contract
holder--the Alaska Pulp Corporation--had breached the contract by
closing its pulp mill in Sitka.  The contract holder in turn filed an
action for breach of contract and unconstitutional taking of property
against the Forest Service.  Litigation is still pending. 

In February 1997, the Clinton administration reached an agreement
with the company holding the remaining long-term timber sale contract
to terminate the contract on December 31, 1999, with a possible
extension to October 31, 2000.  This agreement requires the
company--the Ketchikan Pulp Company--to continue operating two
sawmills in southeastern Alaska, and to clean up specified
environmental damage resulting from its operations in southeastern
Alaska.  In exchange, the administration will supply enough timber to
operate the sawmills for 3 years and will make certain cash payments
to the company.  Each side agreed to release existing or potential
contract claims against the other arising out of the long-term
contract.  In addition, the company agreed to release existing or
potential claims against the United States for the unconstitutional
taking of property related to the long-term contract. 


   FEDERAL LAWS AND REGULATIONS
   PROVIDE A FRAMEWORK FOR
   DEVELOPING FOREST PLANS
--------------------------------------------------------- Appendix I:2

The National Forest Management Act of 1976 (NFMA) requires the Forest
Service to (1) develop a land and resource management plan for each
national forest in coordination with the land and resource management
planning processes of other federal agencies, states, and localities
and (2) revise the plan at least every 15 years.  A forest plan must
sustain multiple uses on the forest and maintain diverse plant and
animal communities (biological diversity).  NFMA's regulations,
issued in 1979 and revised in 1982, require the Forest Service to
estimate the physical, biological, social, and economic effects of
each forest management alternative that the agency considers in
detail in developing, amending, or revising a forest plan.  Economic
effects include the impact on total receipts to the federal
government, direct benefits to forest users, and employment in
affected areas. 

In accordance with the National Environmental Policy Act (NEPA), the
Forest Service must prepare an environmental impact statement to
accompany a forest plan.  In preparing the statement, the agency is
to seek and consider public comments on the potential environmental
and other effects of the proposed forest plan.  NEPA's regulations
require the agency to discuss the direct and indirect effects of the
proposed plan's various alternatives in the statement, including
economic and social effects.  NFMA requires the Forest Service to
make draft plans available to the public for comment for at least 3
months prior to the plan's adoption. 

NFMA's regulations also specify roles and responsibilities for
developing forest plans.  The regulations state that the regional
forester shall establish regional policy for forest planning and
approve all forest plans in the region.  The forest supervisor has
overall responsibility for, among other things, preparing the forest
plan.  The forest supervisor also appoints and supervises an
interdisciplinary team that is charged with developing the forest
plan and its accompanying environmental impact statement.  The team
may consist of whatever combination of Forest Service staff and other
federal personnel is necessary to integrate knowledge of the
physical, biological, economic, and social sciences, as well as the
environment, in the planning process. 


   THE FIRST TONGASS PLAN WAS
   APPROVED IN 1979
--------------------------------------------------------- Appendix I:3

The Tongass was the first national forest to have an approved forest
plan under NFMA.  The Tongass's 1979 forest plan designated certain
areas of the forest off-limits to timber harvesting and scheduled
about 1.7 million of the forest's 5.7 million acres of commercial
forest land as harvestable.  This land was to support an average
annual allowable sale quantity of 450 million board feet.\6

In 1980, the Congress passed the Alaska National Interests Lands
Conservation Act (ANILCA), which created 14 wilderness areas in the
Tongass and designated Admiralty Island and the Misty Fiords as
national monuments.  Following ANILCA's enactment, the Tongass's
commercial forest land was further reduced by about 1.7 million
acres, from 5.7 million acres to about 4 million acres.  ANILCA
directed that at least $40 million derived from timber and other
receipts be made available to the Forest Service to maintain the
timber supply from the Tongass to the dependent forest products
industry at a rate of 4.5 billion board feet per decade.  The Forest
Service amended its 1979 Tongass forest plan in 1986 to reflect
ANILCA's provisions. 


--------------------
\6 The allowable sale quantity is the maximum quantity of timber that
may be sold from an area of suitable land covered by a forest plan
over a decade.  The quantity is usually expressed on an annual basis
as the "average annual allowable sale quantity". 


   THE FOREST SERVICE BEGAN TO
   REVISE THE EXISTING FOREST PLAN
   IN 1987
--------------------------------------------------------- Appendix I:4

In 1987, the Forest Service began to revise the forest plan for the
Tongass.  The agency started by involving the public in a scoping
process to identify issues that would need special attention by the
interdisciplinary team developing the new forest plan.  The team also
started developing a computer database of information about the
resources on the Tongass, such as the location of streams and timber
stands, to provide information on the potential effects of a revised
plan. 

Although the Forest Service's planning regulations specifically
authorize the agency to develop one plan for the entire Tongass, they
do not discuss the planning process in the context of a forest that
is under the jurisdiction of multiple supervisors.  The
organizational structure for the planning effort from 1987 to August
1994 is identified in figure I.3. 

   Figure I.3:  Organizational
   Chart for Planning Team From
   1987 to Mid-1994

   (See figure in printed
   edition.)

The organizational structure for planning consisted of a core
interdisciplinary team headed by a team leader and an assistant team
leader.  Team members included a wildlife biologist, a lands
specialist, a recreation planner, and a timber resource specialist,
among others.  The team leader reported directly to the Chatham
Forest Supervisor, who represented all three forest supervisors and
exercised day-to-day responsibilities for the plan's development. 
The Alaska Region's Director of Ecosystem Planning and Budget offered
planning advice to the interdisciplinary team leader.  In addition,
two groups advised the team.  The first group included the Forest
Service's regional directors for timber, wildlife and fish,
recreation, engineering, lands, minerals, and fish and watersheds. 
The second group consisted of the area planners from each of the
forest's three administrative areas.  This organizational structure
provided the interdisciplinary team with input from each of the three
administrative areas of the forest as well as from the regional
directors who are considered to be the technical experts within the
Forest Service's regional office. 

In June 1990, the Forest Service issued a draft forest plan for
public comment.\7 The draft's analysis centered around 11 issues
identified during scoping:  scenic quality, recreation, fish habitat,
wildlife habitat, subsistence, timber harvest, roads, minerals,
roadless areas, local economy, and wild and scenic rivers.  The draft
presented seven alternatives that the Forest Service could adopt to
manage the Tongass but did not include a preferred alternative. 


--------------------
\7 Tongass Land Management Plan Revision:  Draft Environmental Impact
Statement and Tongass Land Management Revision:  Draft Environmental
Impact Statement, Proposed Revised Forest Plan, USDA, Forest Service,
(June 1990). 


   A VIABLE POPULATION COMMITTEE
   WAS ESTABLISHED TO EXAMINE
   WILDLIFE SPECIES ON THE TONGASS
--------------------------------------------------------- Appendix I:5

The wildlife strategy contained in the 1990 draft of the forest plan
was questioned.  For example, some Forest Service staff from the
three Tongass administrative areas considered the approach too
difficult to implement and not scientifically supportable.  Moreover,
the Forest Service's approach to maintaining diverse wildlife
populations was changing during this time.  For example, in a 1988
decision on the appeal of the approved forest plan for the Flathead
National Forest in northwestern Montana, the Associate Chief of the
Forest Service directed the regional forester to leave 10 percent of
certain watersheds in old-growth areas large enough to provide
habitat for certain species until its regional forester completed
additional analyses of species' habitat requirements.  In addition,
in 1990 an interagency scientific committee released a conservation
strategy for the northern spotted owl in the Pacific Northwest that
advocated retaining large blocks of old-growth forests as a way of
ensuring population viability.\8

In response to concerns regarding the viability of certain old-growth
dependent species on the Tongass, in October 1990 the
interdisciplinary team revising the Tongass's forest plan established
a committee to study the viability of populations of various
old-growth species--the "viable population" committee.  This
committee's principal mission was to identify species whose viability
might be impaired by some forest management activities and to develop
recommendations to maintain viable populations for each such species. 
The committee was not part of the interdisciplinary team. 

Shortly after the committee was established and during the 6-month
period for commenting on the draft Tongass forest plan, the Congress
passed the Tongass Timber Reform Act of 1990.  Among other things,
this act eliminated ANILCA's special funding provision for
maintaining the timber supply from the Tongass, limited timber
harvesting near certain streams, designated additional wilderness
areas within the Tongass, and designated 12 additional special
management areas in which harvesting timber and building roads is
generally prohibited.  The act also made nine modifications to the
long-term timber sale contracts, including adding provisions to the
contracts to prohibit the disproportionate harvest of old-growth
timber.  The Forest Service amended its 1979 Tongass forest plan in
February 1991 to reflect the act's requirements. 


--------------------
\8 Thomas, et al., A Conservation Strategy for the Northern Spotted
Owl:  Report of the Interagency Scientific Committee to Address the
Conservation of the Northern Spotted Owl (1990). 


   THE FOREST SERVICE DECIDED TO
   PREPARE A SUPPLEMENT TO THE
   DRAFT PLAN
--------------------------------------------------------- Appendix I:6

To respond to the Tongass Timber Reform Act and comments received on
the 1990 draft forest plan, which included questions raised about the
adequacy of the wildlife viability analysis in the 1990 draft forest
plan, the Forest Service decided to prepare a supplement to the draft
plan.  In February 1991, the viable population committee submitted a
report to the leader of the interdisciplinary team containing a
proposed strategy for conserving old-growth forest and specific
standards for 13 species dependent on old-growth forest as habitat. 
As foreshadowed by the strategy of the interagency scientific
committee for the Pacific Northwest, the report recommended the use
of large tracts of old-growth reserves close enough together so that
local wildlife populations could interact with each other.  According
to the report, such a system would promote the interchange of genetic
material between populations and maximize the opportunity for
recolonization should one of the populations suffer local extinction. 
The report asserted that this strategy would affect a smaller
proportion of the suitable timber base than was affected by the
interagency scientific committee's strategy or even by the standards
appearing in the 1990 draft forest plan.  The report further
indicated that the recommended standards would only "barely assure
perpetuation" of certain species on the Tongass. 

As the interdisciplinary team prepared the supplement to the draft,
it rejected the strategy recommended by the viability population
committee.  The supplement indicated that the interdisciplinary team
rejected the committee's habitat protection recommendations because
the team considered the evidence supporting the recommendations to be
insufficient.  The draft plan accompanying the supplement provided
(1) for timber sales to be managed so as to maintain large blocks of
old-growth reserves and corridors between the blocks, where
compatible with other resource objectives, and (2) for standards and
guidelines to protect any species that had been identified by the
Fish and Wildlife Service, the National Marine Fisheries Service, or
the Forest Service as threatened, endangered, sensitive, or a
candidate for any of these categories. 

The supplement,\9 issued in September 1991 for public comment,
presented five alternatives, including a preferred alternative.  The
preferred alternative was designed, in the Forest Service's words, to
"enhance the balanced use of resources of the forest and provide a
public timber supply to maintain the Southeast Alaska timber
industry." The alternative proposed an average annual allowable sale
quantity of 418 million board feet--down from the allowable sale
quantity in the 1979 plan of 450 million board feet.  During 1991 and
the spring of 1992, the viable population committee continued to work
on refining and developing its proposed strategy for conserving
wildlife in its February 1991 report and produced a draft report for
review in April 1992.\10 At the request of an Alaska Region official,
a wildlife ecologist from the Pacific Northwest Research Station--a
Portland, Oregon, research arm of the Forest Service--reviewed the
draft report and concluded in July 1992 that the report's wildlife
conservation strategy was sound.  The ecologist urged closer
cooperation between the interdisciplinary team and the viable
population committee and recommended further peer review of the
committee's draft report. 

In December 1992, an Anchorage newspaper published an article
accusing the Forest Service of covering up the information contained
in the viable population committee's draft report and of disregarding
the report's conclusions.  Forest Service officials denied the
accusations and asserted that the viable population committee's
report was only a draft, not yet ready for public distribution, and
that not enough information was available to finalize the report.  In
January 1993, the Chairman of the House Committee on Natural
Resources asked the Secretary of Agriculture to investigate this
matter. 

After the 1991 supplement to the draft forest plan was released for
public comment but before a preferred alternative was selected, the
interdisciplinary team carried out another study of fish and wildlife
viability.  This study was to be included as an appendix--known as
"appendix M"--to the final forest plan.  Appendix M described three
additional risk assessments of wildlife viability performed by the
interdisciplinary team, one of which was based on the viable
population committee's strategy.  The interdisciplinary team stated
in appendix M that these risk assessments amounted only to hypotheses
and required additional data and testing.  In February 1993, the
interdisciplinary team presented a draft of a final revised forest
plan--including a record of decision with a preferred alternative
selected by the forest supervisors--for the regional forester to
sign.  The regional forester did not sign the record of decision. 

Twenty-three conservation biologists and resource scientists sent a
letter to the Vice President in March 1993, condemning the Forest
Service's treatment of its scientists and their work on the Tongass
and the Clearwater National Forest in Idaho.  In June 1993, the House
Committee on Appropriations issued a report to accompany the Forest
Service's fiscal year 1994 appropriations bill directing the Alaska
Region to (1) assist the viable population committee in completing
its report and (2) seek peer review of both the completed report and
appendix M.  The committee completed a draft of its report in May
1993.  By August 1993, the Alaska Region's regional forester
officially requested the Forest Service's Pacific Northwest Research
Station to conduct an independent peer review of these documents. 


--------------------
\9 Tongass Land Management Plan Revision:  Supplement to the Draft
Environmental Impact Statement and Tongass Land Management Plan
Revision:  Supplement to the Draft Environmental Impact Statement,
Proposed Revised Forest Plan, USDA, Forest Service (Aug.  1991). 

\10 Suring, et al., A Strategy for Maintaining Well-Distributed,
Viable Populations of Wildlife Associated with Old-Growth Forests in
Southeast Alaska, review draft (Apr.  1992). 


   THE STRATEGIES FOR PROTECTING
   WILDLIFE WERE PEER REVIEWED
--------------------------------------------------------- Appendix I:7

In March 1994, the Pacific Northwest Research Station released its
report, containing 18 individual scientific reviews, a legal review,
and a summary of the reviews and recommendations.\11 The peer review
gave the viable population committee's draft report generally "high
marks," while concluding that the strategy contained in appendix M
was "not as thorough or well motivated." The peer review indicated
that appendix M needed to go further to meet the requirements of the
relevant legislation. 

The legal review concluded that while the viable population
committee's strategy represented "an earnest, if highly cautious"
attempt to properly implement the Forest Service's regulations for
ensuring wildlife viability and diversity, the proposed appendix's
strategy did "not appear to implement either the spirit or the letter
of these principles." The legal review also expressed doubt about the
consistency of the Forest Service's proposed alternative with the
Tongass Timber Reform Act's restriction on the disproportionate
harvesting of old-growth timber under the long-term contracts.  One
of the scientific reviewers also raised doubts about the legal
validity of the timber harvest plans outlined in the draft revised
forest plan, because the plans appeared to be incompatible with the
agency's own proposed wildlife strategy. 


--------------------
\11 Kiester, et al., Review of Wildlife Management and Conservation
Biology on the Tongass National Forest:  A Synthesis with
Recommendations (1994). 


   A NEW REGIONAL FORESTER
   REDEFINED THE DIRECTION OF THE
   FOREST PLAN REVISION
--------------------------------------------------------- Appendix I:8

At the end of April 1994, the Alaska Region's regional forester
retired.  In May 1994, the Chief of the Forest Service appointed a
new regional forester to the Alaska Region.  The new regional
forester requested that the 1991 supplement to the draft forest plan
be revised to take into account new scientific knowledge about
wildlife viability and new initiatives within the Forest Service,
among other things. 

The regional forester identified five issues on which the revised
supplement would focus: 

  -- wildlife viability because of new information available from the
     viable population committee and other sources;

  -- caves and karst\12 because of the recent discovery of
     world-class karst in the Ketchikan area;

  -- fish and riparian management because of new information arising
     from an--at that time, ongoing--anadromous fish habitat study\13
     required by the Congress and because of the importance of the
     fishing industry to southeastern Alaska;

  -- alternatives to clearcutting because of the Chief's June 1992
     policy to reduce clearcutting in national forests by as much as
     70 percent in order to manage forests in a more environmentally
     sensitive manner; and

  -- socioeconomic effects because of concern about how changes in
     managing the Tongass could affect the timber and other
     industries, especially in light of the then-recent shutdown of
     one of the region's two pulp mills. 


--------------------
\12 Karst consists of areas underlain by soluble rocks, primarily
limestone.  Dissolution of the subsurface strata results in areas of
well-developed surface drainage that are sinkholes, collapsed
channels, or caves. 

\13 Report to Congress:  Anadromous Fish Habitat Assessment, USDA,
Forest Service Pacific Northwest Research Station, Alaska Region
(Jan.  1995). 


   THE NEW REGIONAL FORESTER
   ESTABLISHED A NEW PLANNING TEAM
   STRUCTURE
--------------------------------------------------------- Appendix I:9

In mid-1994, the newly appointed regional forester established a new
planning team structure to revise the 1991 supplement to the draft
Tongass forest plan.  The restructured planning team consisted of two
groups--an interagency policy group and an interdisciplinary team. 
Figure I.4 identifies the revised organizational structure. 

   Figure I.4:  Revised
   Organizational Structure for
   Tongass Planning Team

   (See figure in printed
   edition.)


      THE INTERAGENCY POLICY GROUP
      ADVISED THE
      INTERDISCIPLINARY TEAM
------------------------------------------------------- Appendix I:9.1

The interagency policy group was composed of Alaska Region officials,
including the three forest supervisors; program managers from the
U.S.  Environmental Protection Agency, the Department of the
Interior's Fish and Wildlife Service, and the Department of
Commerce's National Marine Fisheries Service; and personnel from the
State of Alaska.  The group's role was to advise the
interdisciplinary team on the development of the revised supplement
to the draft forest plan and to provide interagency coordination with
other federal and State of Alaska agencies.  The policy group was
disbanded in April 1996 when the revised forest plan was issued for
public comment. 


      THE INTERDISCIPLINARY TEAM
      WAS DIVIDED INTO TWO
      BRANCHES
------------------------------------------------------- Appendix I:9.2

The interdisciplinary team is divided into two branches:  a policy
(also called management) branch and a science branch.  The regional
forester assigned two co-leaders to the interdisciplinary team--a
deputy forest supervisor to head the team's policy branch and a
research scientist to head the science branch.  The policy and
science branches coordinated their efforts to develop alternatives
for managing the Tongass. 


         THE SCIENCE BRANCH
         ADVISED THE POLICY BRANCH
----------------------------------------------------- Appendix I:9.2.1

Under the reorganized planning team structure, research scientists
were appointed to the interdisciplinary team's science branch between
the fall of 1994 and early 1995 by the Director of the Pacific
Northwest Research Station with the concurrence of the regional
forester.  They included scientists with backgrounds in forest
ecology, wildlife biology, social science, hydrology, geology,
forestry, and statistics.  According to Forest Service officials,
scientists were appointed because of concerns about the scientific
credibility of the wildlife strategy in the 1991 supplement to the
draft forest plan. 

The research scientists gathered information primarily on the five
focus issues identified by the regional forester.  They (1) gathered
existing scientific data pertaining to the Tongass, (2) reviewed
various assumptions and strategies used in the plan, and (3)
developed estimates of risks to resources that might result from
various proposed management activities that were eventually included
in the revised supplement to the draft environmental impact
statement.  In addition, they are developing a "reconciliation"
report which examines the extent to which science was considered in
developing the Forest Service's new preferred alternative.  In most
instances, the scientists did not have the time to develop new data
but, rather, relied on information already in existence. 

The regional forester and science branch scientists with whom we
spoke told us that although the research scientists were part of the
interdisciplinary team, they did not participate in developing the
alternatives or selecting the preferred alternative in the revised
supplement to the draft forest plan.  Rather, the research scientists
in the science branch were responsible for (1) gathering information
on the five focus issues and forwarding it to the policy branch and
(2) providing comments and views on related scientific studies and
indicating the risks involved in adopting various management options. 

After the policy branch had developed the alternatives to be included
in the revised supplement to the draft forest plan, the science
branch convened 11 scientific assessment panels of experts and
specialists to evaluate the risk each alternative could pose to the
Tongass National Forest's biological systems, communities, and
wildlife.  Each panel examined the potential effects of the nine
alternatives on one of the following issues:  the Alexander
Archipelago wolf, the northern goshawk, the Sitka black-tailed deer,
the marbled murrelet, the American marten, the brown bear,
terrestrial mammals, fish/riparian areas, old-growth forests,
subsistence, and socioeconomics.  These panels were reconvened in
1997 to assess the alternatives, some of which had been modified
since the revised supplement had been released for public comment in
April 1996. 


         THE POLICY BRANCH
         DEVELOPED ALTERNATIVES
----------------------------------------------------- Appendix I:9.2.2

Many of the policy branch's members were from the prior
interdisciplinary team.  The policy branch included national forest
personnel with backgrounds in fish and wildlife biology, economics,
recreation planning, resource information, wildlife ecology, and
timber planning. 

The policy branch was responsible for developing the alternatives in
the revised supplement of the draft forest plan, managing the
resource database, coordinating public involvement, maintaining
documentation of the planning process, and calculating the impact of
alternatives on the amount of timber available for harvest.  In
developing the alternatives, members of the policy branch considered
the scientific information gathered by the science group as well as
the scientists' comments and views on the risks involved in adopting
various management options.  The two branches also worked together to
summarize the findings of the 11 scientific assessment panels
convened by the science branch and present the summary to the forest
supervisors to aid them in selecting a preferred alternative for
managing the forest.  Alaska Region officials told us that members of
the policy branch chose the various management options, such as the
size of the beach fringe and extent of wild and scenic rivers,
presented in each alternative. 


      FOREST SUPERVISORS PLAYED
      NEW ROLE IN THE RESTRUCTURED
      TEAM
------------------------------------------------------- Appendix I:9.3

Under the planning team structure in effect from 1987 to August 1994,
the Chatham forest supervisor exercised day-to-day responsibility for
developing the revised Tongass forest plan and directly supervised
the interdisciplinary team.  However, under the new regional
forester's new planning team structure, the three forest supervisors
became members of the interagency policy group whose role was to
advise, rather than supervise, the interdisciplinary team in
developing the revised supplement to the draft forest plan.  This new
role of the forest supervisors was controversial both inside and
outside the Forest Service. 

The forest supervisors stated that they were not involved in the
decision to restructure the planning team or in appointing its new
members, including the research scientists.  According to the
supervisors, between August 1994 and September 1995, this new
management structure prevented them from exercising their
decision-making responsibilities under NFMA with respect to
appointing and supervising the interdisciplinary team. 

For example, one forest supervisor told us that the supervisors did
not participate in developing the alternatives or establishing the
scientific assessment panels.  He said that if he had been
responsible for supervising the interdisciplinary team, he would not
have convened the panels because of their anticipated high costs, the
lack of data on which to make informed decisions, and the inadequacy
of similar past efforts. 

According to the deputy forest supervisor assigned by the regional
forester to head the interdisciplinary team's policy branch, he tried
to keep the forest supervisors informed about the interdisciplinary
team's work but generally did not ask them for direction.  In
addition, he told us that the deputy regional manager, rather than
the forest supervisors, had been assigned responsibility for hiring,
firing, and promoting Tongass planning staff between August 1994 and
September 1995. 

The forest supervisors also believe that they were not invited to
participate in some key meetings held by the interagency policy
group.  Other Forest Service officials note that the interagency
policy group was a large, unwieldy body that made few, if any,
decisions. 

According to the regional forester, the forest supervisors informed
him of their concerns in the fall of 1995.  He concluded that the
communication link between the deputy forest supervisor and the
forest supervisors was not working.  He told us that from that point
forward, the supervisors became "reengaged" in the planning process. 
At about this time, the supervisors began to participate in meetings
held by other Forest Service members of the interagency policy group. 
Subsequently, the forest supervisors crafted the preferred
alternative included in the April 1996 revised supplement to the
draft forest plan. 


   THE REVISED SUPPLEMENT TO THE
   DRAFT PLAN WAS RELEASED FOR
   PUBLIC COMMENT
-------------------------------------------------------- Appendix I:10

In April 1996, the Forest Service released the revised supplement to
the draft plan for public comment.\14 The revised supplement differed
substantively from the two previous versions of the draft plan that
had been issued for public comment.  The revised supplement presented
nine alternatives and a preferred alternative.  Each alternative
consisted of variations of ten components:  system and number of
old-growth reserves, rotation age for timber, old growth and
watershed retention, method of timber harvesting, extent of
preservation of karst and caves, extent of riparian protection, size
of beach fringe, estuary protection, timber harvest in watersheds,
and deer winter range. 

The three forest supervisors considered the initial nine alternatives
in the revised supplement before selecting a combination of
components from the alternatives to create their preferred
alternative.  The preferred alternative was published separately from
the bound draft plan, but it was presented in the summary of the
revised supplement along with the other nine alternatives and was
distributed with the rest of the draft plan for comment. 

The preferred alternative incorporated old-growth reserves, an
average 100-year rotation age for timber, a combination of harvesting
methods, a two-aged timber harvest system, a combination of riparian
protection options, and an annual average allowable sale quantity of
357 million board feet per year.  Compared to the 1979 forest plan,
the preferred alternative and the majority of the other alternatives
considered increased the protection of wildlife habitat and decreased
the amount of timber available for harvesting. 


--------------------
\14 Tongass Land Management Plan Revision:  Revised Supplement to the
Draft Environmental Impact Statement and Tongass Land Management Plan
Revision:  Revised Supplement to the Draft Environmental Impact
Statement, Proposed Revised Forest Plan.  Forest Service, Alaska
Region (Mar.  1996). 


      SOCIOECONOMIC EFFECTS WERE
      ADDRESSED
------------------------------------------------------ Appendix I:10.1

The April 1996 revised forest plan and environmental impact statement
for the Tongass placed heavy emphasis on regional socioeconomic
effects.  They did not, however, attempt to quantify the economic
effects on local communities. 

For example, the revised supplement examined the effects of reduced
timber harvesting on the timber, recreation, and fishing industries,
both for the region and for the nation, and expressed these effects
in terms of jobs and income created or lost.  However, for individual
communities, the revised supplement described socioeconomic effects
much more generally than it did for the region as a whole.  The
revised supplement profiled each of southeastern Alaska's 32
communities separately and discussed the composition of each
community's economy.  However, the revised supplement did not
quantify the economic impact but simply stated whether a proposed
alternative would have a negative, positive, or indifferent effect on
the timber, fishing, and recreation sectors of the community's
economy. 

Forest Service economists told us that community-level effects were
not forecast as specifically as were regional economic effects
because not enough information was available about the communities
and about the location of future timber sales.  For example, Forest
Service officials told us that without knowing where a timber sale
will take place and how the timber will be processed, the Forest
Service cannot determine which communities will be affected by timber
sales.  The 1990 draft environmental impact statement and the 1991
supplement to the draft environmental impact statement also did not
attempt to forecast specific effects on individual communities. 


      CONTENT ANALYSIS ON PUBLIC
      COMMENTS WAS DONE BY AN
      IN-HOUSE CONTRACTOR
------------------------------------------------------ Appendix I:10.2

In the fall of 1995, the interdisciplinary team revising the Tongass
plan realized that, because of the significant media attention and
public response to Tongass planning issues, the public comments
received on the revised supplement to the draft forest plan would
likely be too numerous for them to process effectively.  After
considering a few outside contractors who had experience in content
analysis, the interdisciplinary team hired an in-Service "enterprise
team"\15 consisting of agency employees working outside of the Alaska
Region and specializing in content analysis.  The interdisciplinary
team estimated that the enterprise team would be more costly to hire
than an outside contractor--$160,000 for the in-Service team compared
with $80,000 to $150,000 for an outside team.  However, the
interdisciplinary team believed that the advantages of hiring the
in-Service team outweighed the higher cost.  These advantages
included (1) a much faster start-up time with less demand on the
interdisciplinary team's time; (2) a more thorough knowledge of
national forest issues; and (3) a familiarity with forest plans,
terms, and concepts. 

After the revised supplement to the draft plan was released for
public comment, the Forest Service held open houses and hearings in
southeastern Alaska's 32 communities, met with interested groups, and
discussed the proposed revised plan on local media.  The revised
supplement to the draft also generated public meetings and
demonstrations as well as congressional hearings.  In July 1996, the
regional forester granted a 30-day extension (through late Aug. 
1996) to the 90-day comment period after considering the public
comments received to date and the interest shown by the public in
extending the comment period. 

About 21,000 respondents submitted comments.  In comparison, for the
1990 and 1991 drafts released for public comment, the Forest Service
received comments from about 3,700 and 7,300 respondents,
respectively. 

Between June 1996 and October 1996, the in-Service team analyzed the
public comments.  Substantive issues, concerns, and questions raised
by commenters were identified by the in-Service team and given to the
interdisciplinary team for consideration in developing the revision
to the final plan.  The in-Service team, working primarily on the
Flathead National Forest, consisted of about 40 people, including a
project coordinator, 2 team leaders, computer support staff,
writers/coders, data entry staff, and editors.  In addition, Alaska
regional staff assisted the in-Service team.  Prior to working on the
Tongass plan, the project coordinator had performed content analyses
for several projects, including NFMA regulations, national forest
plans, and environmental impact statements and environmental
assessments.  Most of the coding staff were planners or resource
specialists with the National Forest System.  The project coordinator
told us that because the team was not from the Tongass National
Forest, the team provided an objective, third-party view of the
public comments. 

In early October 1996, the in-Service team prepared the final draft
content analysis summary displaying demographic information and
specific issue-by-issue analysis in a summary of public comments. 
According to the content analysis done by the in-Service team, (1)
the majority of the public comments concerned the level of timber
harvesting that the preferred alternative allowed, (2) over half the
comments supported lowering the amount of timber available for
harvesting and suggested terminating or not extending the Tongass's
remaining long-term timber-harvesting contract, and (3) many of the
respondents, especially southeastern Alaskans, were worried about the
social and economic effects on their communities if the preferred
alternative was selected. 

The Tongass official responsible for overseeing the work done by the
in-Service content analysis team considered the team's work to be
accurate and timely, given the large database that the team had to
work with and the time constraints placed on the team.  The total
cost for the in-Service contract was $185,000. 


--------------------
\15 The Forest Service recently instituted an "enterprise team"
concept that brings together people with certain skills and
experiences in certain areas, such as audio/visual presentation,
science assessment, or content analysis, that can be used throughout
the National Forest System. 


   THE NEW REGIONAL FORESTER ACTED
   TO INVOLVE REGULATORY AGENCIES
   IN REVISING PLAN
-------------------------------------------------------- Appendix I:11

As discussed earlier, in mid-1994 the newly appointed regional
forester established a new planning team structure to revise the 1991
supplement to the draft Tongass forest plan.  Under the new
structure, the regulatory agencies were members of the interagency
policy group established to advise the interdisciplinary team and to
improve interagency coordination. 

Interagency coordination became increasingly important in December
1993 when the Fish and Wildlife Service received a petition to list
the Alexander Archipelago wolf as threatened under the Endangered
Species Act.  In addition, in May 1994 the Fish and Wildlife Service
received a petition to list the Queen Charlotte goshawk as endangered
under the act.  Both subspecies occur on the Tongass and are
dependent on old-growth forest as habitat.  The revised Tongass
forest plan, when issued, would impact how these subspecies' habitat
is managed and so could be a determinant in the viability of the
species. 

Besides involving the Fish and Wildlife Service in the interagency
policy group, in December 1994 the Forest Service signed a memorandum
of understanding with the Fish and Wildlife Service and the Alaska
Department of Fish and Game to prevent the listing of species on the
Tongass as endangered or threatened.  The memorandum provided that
the agencies should assess wildlife habitat, share information about
species they manage, and meet regularly to discuss the status of
species to reduce the need to list them under federal or state
endangered species acts. 

In addition, the Forest Service's Alaska Region also acted
independently to prevent the listing of the wolf, the goshawk, and
other species: 

  -- In June 1994, the regional forester deferred timber harvesting
     in old-growth reserves that had been identified by the viable
     population committee as needed to maintain viable populations of
     old-growth-dependent species.

  -- In September 1994, the Forest Service issued for comment an
     environmental assessment intended to protect the wildlife
     habitat of such species as the goshawk and the wolf while
     maintaining a supply of timber for local industry.  The proposed
     action in the environmental assessment was to provide interim
     management guidelines to protect the species until the revised
     supplement to the draft forest plan was approved.  If
     implemented, the guidelines were intended to protect those areas
     identified by the viable population committee as needed to
     maintain viable populations of old-growth-dependent species. 
     This action was predicted to "likely result in measurably lower
     timber sale offerings to independent mills," as well as defer
     some timber sale offerings for the Tongass's remaining long-term
     contract.  In July 1995, the Congress passed an act\16
     containing a rider effectively prohibiting the Forest Service
     from implementing the management guidelines.  Accordingly, the
     regional forester did not sign the environmental assessment or
     implement the guidelines. 

In 1995, the Fish and Wildlife Service found that listing the wolf
and the goshawk under the Endangered Species Act was not warranted. 
Environmental plaintiffs challenged these decisions.  In September
1996, as the Forest Service was reviewing public comments on the
revised supplement to the draft plan and formulating an alternative
intended to become the final Tongass forest plan, a federal district
court remanded the Fish and Wildlife Service's decision on the
goshawk to the agency.  In October 1996, the same court reached the
same decision with respect to the wolf.  In each case, the court
ruled that the Fish and Wildlife Service's basis for not listing the
subspecies--that the revised Tongass forest plan would provide
adequate protection for the species' habitats--was not valid, since
the plan had not yet been formally approved by the Forest Service. 
Instead, the court held that the Fish and Wildlife Service must base
its decision on the current (1979, as amended) plan and the current
status of the subspecies and its habitat. 

As a result of these court decisions, the Fish and Wildlife Service
began negotiations with the Forest Service in an attempt to ensure
that the final forest plan would prevent the need to list the goshawk
or the wolf as endangered.  The Fish and Wildlife Service has until
May 31, 1997, to reach a decision on the status of these species. 

Despite the involvement of federal regulatory and state agencies in
developing the revised supplement to the draft forest plan, the
Environmental Protection Agency, the Fish and Wildlife Service, and
the National Marine Fisheries Service submitted comments on the draft
that criticized the preferred alternative as posing a high level of
risk to wildlife and habitat.  The Fish and Wildlife Service was
concerned that harvesting timber on a 100-year rotation, as proposed
in the preferred alternative, would prevent forests from recovering
old-growth stand characteristics, resulting in the loss of viable
populations of species that depend on old-growth forests for habitat. 
The Environmental Protection Agency and the National Marine Fisheries
Service favored more expansive riparian protection than the preferred
alternative provided to protect fish habitat and water quality. 


--------------------
\16 Emergency Supplemental Appropriations for Additional Disaster
Assistance, for Anti-Terrorism Initiatives, for Assistance in the
Recovery From the Tragedy That Occurred at Oklahoma City, and
Rescissions Act, 1995, P.L.-104-19. 


ESTIMATED COST OF THE TONGASS
PLANNING PROCESS
========================================================== Appendix II

During the 10 years from fiscal year 1987 through fiscal year 1996,
the Forest Service's Alaska Region spent slightly over $13 million to
develop the revised Tongass land management plan and environmental
impact statement.  Tables II.1 and II.2 show the sources of the funds
used and the cost elements charged to develop the forest plan.  The
tables' totals for budgeting and spending may not match because of
rounding. 



                                        Table II.1
                         
                         Budget Line Item Categories for Funding
                          the Development of the Tongass Forest
                              Plan for Fiscal Years 1987-96

                                  (Dollars in thousands)

                                                Fiscal year
                         ----------------------------------------------------------
Expanded budget line                                                                 Tota
item                     1987  1988  1989  1990  1991  1992  1993  1994  1995  1996     l
-----------------------  ----  ----  ----  ----  ----  ----  ----  ----  ----  ----  ----
Ecosystem management       $0    $0    $0    $0    $0    $0    $0    $0  $2,0  $1,9  $4,0
                                                                           56    86    42
Minerals                   44     0    30    46    59    32    35    24     0     0   270
Timber management          29     0    47    93    89   796   790   603     0   135  2,58
                                                                                        1
Forest vegetation           0     0     0     0     0     0     0     0     0    20    20
 management
Recreation                 44     0    80   140   118    99   123    90     0     0   694
Wildlife and fish          29     0    47    78   103    59    55    38     0     0   409
Soil, water, and air       23     0    78   141   162   105    96    67     0     0   672
Road construction          21     0    24    47    30    35    58    41   113    90   459
Tongass timber supply\a   102   982   761  1,00   915     0     0     0     0     0  3,76
                                              8                                         9
Anadromous fish habitat     0     0     0     0     0     0     0   100     0    54   154
 assessment
=========================================================================================
Total                    $292  $982  $1,0  $1,5  $1,4  $1,1  $1,1  $963  $2,1  $2,2  $13,
                                       67    53    76    26    57          69    85   070
-----------------------------------------------------------------------------------------
Note:  Totals may not add because of rounding. 

\a The Alaska National Interests Lands Conservation Act (ANILCA) of
1980 directed that at least $40 million be made available annually to
support, among other things, a timber supply from the Tongass
National Forest.  This money went into the Tongass timber supply
fund.  The Tongass Timber Reform Act of 1990 repealed this ANILCA
provision, and the fund ceased to exist at the end of fiscal year
1991. 

Source:  Forest Service's Alaska Region. 

As table II.1 shows, during fiscal years 1987-96, $13 million was
funded from numerous Forest Service accounts to develop the plan,
including ecosystem management; minerals; timber management;
recreation; wildlife and fish; soil, water, and air; road
construction; and Tongass timber supply.  Forest Service officials
were unable to provide us with information on their rationale for
using the various funding accounts for fiscal years 1987-94.  For
fiscal years 1995 and 1996, the Forest Service began budgeting most
of the funding for the plan from the ecosystem management account. 
An Alaska Region budget officer told us that the ecosystem management
account was established to finance large-scale planning efforts such
as the Tongass plan. 



                                        Table II.2
                         
                         Cost Category for the Development of the
                           Tongass Forest Plan for Fiscal Years
                                         1987-96

                                  (Dollars in thousands)

                                                Fiscal year
                         ----------------------------------------------------------
                                                                                     Tota
Cost element             1987  1988  1989  1990  1991  1992  1993  1994  1995  1996     l
-----------------------  ----  ----  ----  ----  ----  ----  ----  ----  ----  ----  ----
Salary                   $216  $383  $554  $808  $761  $690  $716  $615  $852  $960  $6,5
                                                                                       55
Vehicle and equipment       1     1     0     0     1     0     0     1     0     0     4
 rental
Materials and supplies      5    25    29    16    14     9    31    32    23    21   205
Construction and            0   495    60   166   186    98    61    39   184   264  1,55
 services                                                                               3
Travel and training        24    50    84    82   104    66    63    25   132   116   746
Commercial rents/           1     7    20    77    70    82    73    73    82    83   568
 utilities
Automated data              0     6   208   298   295   135    21    19   195   184  1,36
 processing                                                                             1
Transfer of station         2     0     0     0     0     0     0     0     0    62    64
Other                      44    15   114   103    45    45   191   161  702\  594\  2,01
                                                                            a     a     4
=========================================================================================
Total                    $293  $982  $1,0  $1,5  $1,4  $1,1  $1,1  $965  $2,1  $2,2  $13,
                                       69    50    76    25    56          70    84   070
-----------------------------------------------------------------------------------------
Note:  Totals may not add because of rounding. 

\a Includes Pacific Northwest Research Station services of $463,000
in 1995 and $570,000 in 1996.  About $515,000 of these costs are for
personnel salaries. 

Source:  GAO's analysis of data provided by the Forest Service. 

As table II.2 shows, slightly more than $13 million was spent for
salaries, travel, training, space leasing/utilities,
printing/publishing, computer workstation leases/computer support
services, and other equipment and supplies.  Over $7 million, or 54
percent of the $13 million, was spent for staff salaries.  An Alaska
Region budget officer told us that some Tongass planning costs
incurred by the regional forester, forest supervisors, some regional
office administrative personnel, and Forest Service headquarters
personnel are not included in these planning costs and are not
readily available. 


*** End of document. ***