Forest Service Decision-Making: Greater Clarity Needed on Mission
Priorities (Testimony, 02/25/97, GAO/T-RCED-97-81).
GAO discussed the preliminary results of its work on the decisionmaking
process used by the Forest Service in carrying out its mission, focusing
on the underlying causes of inefficiencies and ineffectiveness in the
Forest Service's decisionmaking process.
GAO noted that: (1) its ongoing work has identified three underlying
causes of inefficiency and ineffectiveness in the Forest Service's
decisionmaking process; (2) first, the agency has not given adequate
attention to improving its decisionmaking process, including improving
its accountability for expenditures and performance; (3) as a result,
long-standing deficiencies within its decisionmaking process that have
contributed to increased costs and time and/or the inability to achieve
planned objectives have not been corrected; (4) second, issues that
transcend the agency's administrative boundaries and jurisdiction have
not been adequately addressed; (5) in particular, the Forest Service and
other federal agencies have had difficulty reconciling the
administrative boundaries of national forests, parks, and other federal
land management units with the boundaries of natural systems, such as
watersheds and vegetative and animal communities, both in planning and
in assessing the cumulative impact of federal and nonfederal activities
on the environment; (6) third, the requirements of numerous planning and
environmental laws, enacted during the 1960s and 1970s, have not been
harmonized; (7) as a result, differences among the requirements of
different laws and their differing judicial interpretations require some
issues to be analyzed or reanalyzed at different stages in the different
decisionmaking processes of the Forest Service and other federal
agencies without any clear sequence leading to their timely resolution;
(8) additional differences among the statutory requirements for
protecting resources, such as endangered and threatened species, water,
air, diverse plant and animal communities, and wilderness, have also
sometimes been difficult to reconcile; (9) however, on the basis of its
work to date, GAO believes that statutory changes to improve the
efficiency and effectiveness of the Forest Service's decisionmaking
process cannot be identified until agreement is first reached on which
uses the agency is to 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 (10) disagreement over
which uses should receive priority, both inside and outside the agency,
has also inhibited the Forest Service in establishing the goals and
performance measures needed to ensure its accountability.
--------------------------- Indexing Terms -----------------------------
REPORTNUM: T-RCED-97-81
TITLE: Forest Service Decision-Making: Greater Clarity Needed on
Mission Priorities
DATE: 02/25/97
SUBJECT: Land management
National forests
Environmental law
Natural resources
Strategic planning
Forest management
Accountability
Jurisdictional authority
Interagency relations
IDENTIFIER: Forest Service Timber Sales Program
Columbia River Basin (WA)
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Cover
================================================================ COVER
Before the Subcommittee on Forests and Public Lands Management,
Committee on Energy and Natural Resources, U. S. Senate
For Release on Delivery
Expected at
2:30 p.m. EST
Tuesday
February 25, 1997
FOREST SERVICE DECISION-MAKING -
GREATER CLARITY NEEDED ON MISSION
PRIORITIES
Statement of Barry T. Hill, Associate Director,
Energy, Resources, and Science Issues,
Resources, Community, and Economic,
Development Division
GAO/T-RCED-97-81
GAO/RCED-97-81T
(141031)
Abbreviations
=============================================================== ABBREV
MR. CHAIRMAN AND MEMBERS OF THE
SUBCOMMITTEE:
============================================================ Chapter 0
We are pleased to be here today to discuss the preliminary results of
our work for you and other requesters on the decision-making process
used by the Department of Agriculture's Forest Service in carrying
out its mission. Your draft bill--entitled the Public Land
Management Responsibility and Accountability Restoration Act--is
designed to provide the Forest Service and the Department of the
Interior's Bureau of Land Management with the authority and ability
to effectively manage their lands in accordance with the principles
of multiple use and sustained yield and for other purposes. It does
this by supplementing the agencies' planning statutes and other laws
that apply to lands managed by the two agencies. As agreed, to help
frame the discussion on your draft bill, we will present our
preliminary views on the underlying causes of inefficiencies and
ineffectiveness in the Forest Service's decision-making process.
During hearings held during the 104th Congress, we and others
testified\1 that the Forest Service's decision-making process is
costly and time-consuming and that the agency often fails to achieve
its planned objectives. The agency has spent over 20 years and over
$250 million developing multiyear plans for managing timber
production, livestock grazing, recreation, wildlife and fish habitat,
and other legislatively mandated uses on national forests. It also
spends about $250 million a year for environmental studies to support
individual projects. However, according to an internal Forest
Service report, inefficiencies within this process cost up to $100
million a year at the project level alone. In addition, by the time
the agency has completed its decision-making, it often finds that it
is unable to achieve the plans' objectives or implement planned
projects because of changes in natural conditions and funding, as
well as new information and events.
In summary, Mr. Chairman, our ongoing work has identified three
underlying causes of inefficiency and ineffectiveness in the Forest
Service's decision-making process:
-- First, the agency has not given adequate attention to improving
its decision-making process, including improving its
accountability for expenditures and performance. As a result,
long-standing deficiencies within its decision-making process
that have contributed to increased costs and time and/or the
inability to achieve planned objectives have not been corrected.
-- Second, issues that transcend the agency's administrative
boundaries and jurisdiction have not been adequately addressed.
In particular, the Forest Service and other federal agencies
have had difficulty reconciling the administrative boundaries of
national forests, parks, and other federal land management units
with the boundaries of natural systems, such as watersheds and
vegetative and animal communities, both in planning and in
assessing the cumulative impact of federal and nonfederal
activities on the environment.
-- Third, the requirements of numerous planning and environmental
laws, enacted primarily during the 1960s and 1970s, have not
been harmonized. As a result, differences among the
requirements of different laws and their differing judicial
interpretations require some issues to be analyzed or reanalyzed
at different stages in the different decision-making processes
of the Forest Service and other federal agencies without any
clear sequence leading to their timely resolution. Additional
differences among the statutory requirements for protecting
resources--such as endangered and threatened species, water,
air, diverse plant and animal communities, and wilderness--have
also sometimes been difficult to reconcile.
However, on the basis of our work to date, we believe that statutory
changes to improve the efficiency and effectiveness of the Forest
Service's decision-making process cannot be identified until
agreement is first reached on which uses the agency is to 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. Disagreement over which uses should receive priority, both
inside and outside the agency, has also inhibited the Forest Service
in establishing the goals and performance measures needed to ensure
its accountability.
--------------------
\1 See, for example, Forest Service: Issues Relating to Its
Decisionmaking Process (GAO/T-RCED-96-66, Jan. 25, 1996) and Forest
Service: Issues Related to Managing National Forests for Multiple
Uses (GAO/T-RCED-96-111, Mar. 26, 1996).
THE FOREST SERVICE HAS NOT
GIVEN ADEQUATE ATTENTION TO
IMPROVING ITS DECISION-MAKING
PROCESS
---------------------------------------------------------- Chapter 0:1
Reducing the costs and time of its decision-making and improving its
ability to deliver what is expected or promised have not been given
adequate attention throughout the Forest Service. As a result,
deficiencies within the decision-making process that have been known
to the agency for a decade or more have not been corrected. To
compensate for the increased costs and time of decision-making and
the inability to implement planned projects, the Forest Service must
request more annual appropriations to achieve fewer planning
objectives.
The Chief Financial Officers Act of 1990 requires the agency to be
more accountable for its expenditures of appropriated funds by
requiring it to develop integrated accounting and financial
management systems that are to provide complete, reliable,
consistent, and timely financial information. However, the Forest
Service has made little progress in implementing the act's
provisions. An audit of the agency's financial statements for fiscal
year 1995 by Agriculture's Inspector General resulted in an adverse
opinion because of "pervasive errors, material or potentially
material misstatements, and/or departures from applicable Government
accounting principles affecting several Financial Statement
accounts."\2 Among the audit's findings, the Inspector General
reported that the Forest Service could not account for expenditures
of $215 million in fiscal year 1995. As a result, Forest Service
managers are unable to adequately monitor and control spending levels
for various programs and activities relating to decision-making or to
measure the extent to which changes affect costs and efficiency.
Corrective actions to address accounting and financial reporting
problems identified by the Inspector General are not scheduled to be
implemented until the end of fiscal year 1998.
Similarly, the Forest Service has not been successful in achieving
the objectives in its forest plans or implementing planned projects.
For example, in response to congressional concerns about the Forest
Service not being able to deliver what is expected or promised, the
Chief, in the fall of 1991, formed a task force of employees from
throughout the agency to review the issue of accountability. The
task force's February 1994 report set forth a seven-step process to
strengthen accountability. Steps in the process include (1)
establishing work agreements that include measures and standards with
customer involvement, (2) assessing performance, and (3)
communicating results to customers. However, the task force's
recommendations were never implemented. Rather, they were identified
as actions that the agency plans to implement over the next decade.
The task force's recommendations, as well as those in other studies,
are intended to address some of the long-standing deficiencies within
the Forest Service's decision-making process that have driven up
costs and time and/or driven down the ability to achieve planned
objectives. These deficiencies include (1) not adequately monitoring
the effects of past management decisions, (2) not maintaining a
centralized system of comparable environmental and socioeconomic
data, and (3) not adequately involving the public throughout the
decision-making process.
For example, adequate monitoring of the effects of past management
decisions is critical to accurately estimate the effects of similar
future decisions, including their cumulative impact. Moreover,
monitoring can be used as an effective tool when the effects of a
decision may be difficult to determine in advance because of
uncertainty or costs. However, the Forest Service (1) has
historically given low priority to monitoring during the annual
competition for scarce resources, (2) continues to approve projects
without an adequate monitoring component, and (3) does not require
its managers to report on the results of monitoring, as its current
regulations require.
Because of the inefficiencies in its decision-making process, the
Forest Service must request more funds to accomplish fewer objectives
during the yearly budget and appropriation process. For example, in
fiscal year 1991, the Congress asked the Forest Service to develop a
multiyear program to reduce the costs of its timber program by not
less than 5 percent per year. The Forest Service responded to these
and other concerns by undertaking three major cost-efficiency studies
and is preparing to undertake a fourth. However, with no incentive
to act, the agency has not implemented any of the recommended
improvements agencywide. In the interim, the costs associated with
preparing and administering timber sales have continued to rise. As
a result, for fiscal year 1998, the agency is requesting $12 million,
or 6 percent, more for timber sales management than was appropriated
for fiscal year 1997 while proposing to offer 0.4 billion board feet,
or 10 percent, less timber for sale.
The Government Performance and Results Act of 1993 is designed to
hold federal agencies more accountable for their performance by
requiring them to establish performance goals, measures, and reports
that provide a system of accountability for results. In addition,
the Clinger-Cohen Act of 1996 (formerly entitled the Information
Technology Management Reform Act of 1996) and the Paperwork Reduction
Act of 1995 are intended to hold federal agencies more accountable
for the adequacy of their information systems and data by providing
that they shall establish goals, measure performance, and report on
how well their information technology and data are supporting their
mission-related programs. Although it is still too early to tell
what impact these laws, together with the Chief Financial Officers
Act, will have on the Forest Service, they provide a useful framework
for strengthening accountability within the agency and improving the
efficiency and effectiveness of its decision-making.
--------------------
\2 Audit of Forest Service's Fiscal Year 1995 Financial Statements
(Audit Report No. 08401-4-At, Office of Inspector General,
Department of Agriculture).
INTERAGENCY ISSUES AFFECT THE
FOREST SERVICE'S
DECISION-MAKING
---------------------------------------------------------- Chapter 0:2
Issues that transcend the agency's administrative boundaries and
jurisdiction also affect the efficiency and effectiveness of the
Forest Service's decision-making process. These issues include
reconciling differences in the geographic areas that must be
considered in reaching decisions under different planning and
environmental laws.
The Forest Service and other federal land management agencies are
authorized to plan primarily along administrative boundaries, such as
those defining national forests and parks. Conversely, environmental
statutes and regulations require the agencies to analyze
environmental issues and concerns along the boundaries of natural
systems, such as watersheds and vegetative and animal communities.
For example, regulations implementing the National Environmental
Policy Act require the agencies to assess the cumulative impact of
federal and nonfederal activities on the environment.
Because the boundaries of administrative units and natural systems
are frequently inconsistent, federal land management plans have often
considered effects only on portions of natural systems or portions of
the habitats of wide-ranging species, such as migratory birds, bears,
and anadromous fish (including salmon). For example, the Interior
Columbia River Basin contains 74 separate federal land units,
including 35 national forests and 17 Bureau of Land Management
districts, each with its own plan. Not analyzing effects on natural
systems and their components at the appropriate ecological scale
results in duplicative environmental analyses--in individual plans
and projects--increasing the costs and time required for analysis and
reducing the effectiveness of federal land management
decision-making.
Addressing issues that transcend the administrative boundaries and
jurisdictions of the Forest Service and of other federal agencies
will, at a minimum, require unparalleled coordination and cooperation
among federal agencies. However, federal land management and
regulatory agencies sometimes do not work efficiently and effectively
together to address issues that transcend their boundaries and
jurisdictions. Disagreements often stem from differing evaluations
of environmental effects and risks, which in turn reflect the
agencies' disparate missions and responsibilities.
Effective interagency coordination, in turn, requires comparable
environmental and socioeconomic data. However, the data gathered by
federal agencies are often not comparable, large gaps in the
information exist, and federal agencies lack awareness of who has
what information.
Over the past few years, several major studies have examined the need
to reconcile the differences in the geographic areas that federal
agencies must consider when reaching decisions.\3 Among the options
that have been suggested are changes to the Council on Environmental
Quality's regulations and guidance implementing the procedural
provisions of the National Environmental Policy Act. According to
Council officials, changes to the act's regulations and guidance are
not being considered at this time. Instead, the Council plans to
rely primarily on less binding interagency agreements. However,
since federal agencies sometimes do not work efficiently and
effectively together to address issues that transcend their
boundaries and jurisdictions and often lack the environmental and
socioeconomic data required to make informed decisions, strong
leadership by the Council would help to ensure that interagency
agreements accomplish their intended objectives.
--------------------
\3 See, for example, The Ecosystem Approach: Healthy Ecosystems and
Sustainable Economies, Volume II - Implementation Issues, Report of
the Interagency Ecosystem Management Task Force (Nov. 1995);
Ecosystem Management: Additional Actions Needed to Adequately Test a
Promising Approach (GAO/RCED-94-111, Aug. 16, 1994); and Final
Report of Recommendations: Project-Level Analysis Re-Engineering
Team, Forest Service (Nov. 17, 1995).
DIFFERENCES IN LAWS AFFECT THE
FOREST SERVICE'S
DECISION-MAKING
---------------------------------------------------------- Chapter 0:3
Finally, differences in the requirements of numerous planning and
environmental laws, enacted primarily during the 1960s and 1970s,
produce inefficiency and ineffectiveness in the Forest Service's
decision-making. Differences among their requirements and differing
judicial interpretations of their requirements have caused some
issues to be analyzed or reanalyzed at various stages in the Forest
Service's decision-making process, as well as in the decision-making
processes of other federal agencies, without their timely resolution,
increasing the costs and time of decision-making and reducing the
ability of the Forest Service and other land management agencies to
achieve the objectives in their plans.
New information and events can affect the outcomes of the Forest
Service's decisions and prevent the agency from achieving the
objectives in its forest plans or implementing planned projects. For
instance, the listing of a species as endangered or threatened under
the Endangered Species Act after a forest plan has been approved
requires the Forest Service to reinitiate formal consultations with
the Fish and Wildlife Service and/or the National Marine Fisheries
Service to amend or revise the plan. The listing may also prohibit
the agency from implementing projects under the plans that may affect
the species until the new round of consultations has been completed.
For example, recent federal court decisions required the Forest
Service to reinitiate consultations on several approved forest plans
after a species of salmon in the Pacific Northwest and a species of
owl in the Southwest were listed as threatened under the Endangered
Species Act. The courts' rulings prohibited the agency from
implementing projects under the plans that might affect the species
until the new rounds of consultations with the Fish and Wildlife
Service and/or the National Marine Fisheries Service had been
completed.
Additionally, through differing judicial interpretations of the same
statutory requirements, the courts have established conflicting
requirements. For example, three federal circuit courts of appeals
have held that the approval of a forest plan represents a decision
that can be judicially challenged and prohibited from being
implemented. Conversely, two other federal circuit courts of appeals
have held that a forest plan does not represent a decision and that
only a project can be judicially challenged, at which time the
adequacy of the plan's treatment of larger-scale environmental issues
arising in the project can be reconsidered.
Requirements to consider new information and events, coupled with
differing judicial interpretations of the same statutory
requirements, have made it difficult for the Forest Service and other
federal agencies to predict when any given decision can be considered
final and can be implemented. Agency officials perceive that the
same issues are recycled under different planning and environmental
laws rather than resolved in a timely manner.
In addition, environmental laws generally address individual
resources, such as endangered and threatened species, water, and air.
Conversely, planning statutes generally establish objectives for
multiple resources, such as sustaining diverse plant and animal
communities, securing favorable water flow conditions, and preserving
wilderness. These different approaches to achieving similar
environmental objectives have sometimes been difficult for the Forest
Service and other federal agencies to reconcile, at least in the
short term. For example, prescribed burning to restore the forests'
health and to sustain diverse plant and animal communities may be
appropriate under the National Forest Management Act but may be
difficult to reconcile in the short term with air quality standards
under the Clean Air Act.
In March 1995, the Secretary of Agriculture pledged to work with the
Congress to identify statutory changes to improve the processes for
implementing the Forest Service's mission. However, neither his
analysis nor options for changing the current statutory framework
suggested by the Forest Service in 1995 have been sent to the
Congress. Administration officials have said that they are hesitant
to suggest changes to the procedural requirements of planning and
environmental laws because they believe that the Congress may also
make substantive changes to the laws with which they would disagree.
THE FOREST SERVICE NEEDS
GUIDANCE ON HOW TO RESOLVE
CONFLICTS AMONG COMPETING USES
---------------------------------------------------------- Chapter 0:4
On the basis of our work to date, we believe that statutory changes
to improve the efficiency and effectiveness of the Forest Service's
decision-making process cannot be identified until after agreement is
reached on which uses the agency is to 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.
Our report to you and other requesters, to be issued this spring,
will identify the increasing shift in emphasis in the Forest
Service's plans from producing timber to sustaining wildlife and
fish. This shift is taking place in reaction to requirements in
planning and environmental laws--reflecting changing public values
and concerns--and their judicial interpretations, together with
social, ecological, and other factors. In particular, section 7 of
the Endangered Species Act represents a congressional design to give
greater priority to the protection of endangered species than to the
current primary missions of the Forest Service and other federal
agencies.\4 When proposing a project, the Forest Service bears the
burden of proof to demonstrate that its actions will not likely
jeopardize listed species.
The increasing emphasis on sustaining wildlife and fish conflicts
with the older emphasis on producing timber and underlies the Forest
Service's inability to achieve the goals and objectives for timber
production set forth in many of the first forest plans. In addition,
this attention to sustaining wildlife and fish will likely constrain
future uses of the national forests, such as recreation. The demand
for recreation is expected to grow and may increasingly conflict with
both sustaining wildlife and fish and producing timber on Forest
Service lands.
While the agency continues to increase its emphasis on sustaining
wildlife and fish, the Congress has never explicitly accepted this
shift in emphasis or acknowledged its effects on the availability of
other uses on national forests. Disagreement over the Forest
Service's priorities, both inside and outside the agency, has not
only hampered efforts to improve the efficiency and effectiveness of
its decision-making but also inhibited it in establishing the goals
and performance measures needed to ensure its accountability.
If agreement is to be reached on efforts to improve the Forest
Service's decision-making and if the agency is to be held accountable
for its expenditures and performance, the Forest Service will need to
consult with the Congress on its strategic long-term goals and
desired outcome measures, as the Government Performance and Results
Act requires. Such a consultation would create an opportunity for
the Forest Service to gain a better understanding of which uses it is
to 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.
--------------------
\4 TVA v. Hill, 437 U.S. 153, 185 (1978).
-------------------------------------------------------- Chapter 0:4.1
In summary, Mr. Chairman, the Forest Service's decision-making
process is broken and in need of repair. While much can be done
within the current statutory framework to improve the efficiency and
effectiveness of the process, strong leadership, both throughout the
Forest Service and within the Council on Environmental Quality, will
be required. Moreover, sustained oversight by the Congress will also
be important.
Differences among the requirements of planning and environmental laws
also need to be addressed. However, at a June 1996 hearing at which
both you and we testified,\5 you stressed that "form must follow
function" and that the immediate priority is to clarify the Forest
Service's functions. We agreed with you then, and we agree with you
now. Clarifying priorities within the Forest Service's multiple-use
and sustained-yield mission should provide the agency with a better
understanding of which uses it is to 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. Once
this is done, the legislative changes that are needed to clarify or
modify congressional intentions and expectations can be identified.
--------------------
\5 See Transcript of Proceedings, U. S. Senate, Committee on
Governmental Affairs, Improving Management and Organization in
Federal Natural Resources and Environmental Functions (June 27, 1996)
and Federal Land Management: Streamlining and Reorganization Issues
(GAO/T-RCED-96-209, June 27, 1996).
*** End of document. ***