[Advisory Report on the Resource Advisory Councils, Rangeland Management Program, Bureau of Land Management]
[From the U.S. Government Printing Office, www.gpo.gov]

Report No. 98-I-646

Title: Advisory Report on the Resource Advisory Councils, Rangeland
       Management Program, Bureau of Land Management

Date:  September 21, 1998




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U.S. Department of the Interior
Office of Inspector General






ADVISORY REPORT


RESOURCE ADVISORY COUNCILS,
RANGELAND MANAGEMENT PROGRAM,
BUREAU OF LAND MANAGEMENT

REPORT NO. 98-I-646
SEPTEMBER 1998





MEMORANDUM


TO:               The Secretary

FROM:             Richard N. Reback
                  Acting  Inspector General

SUBJECT SUMMARY:  Final Advisory Report for
                  Your  Information  -  "Resource  Advisory
                  Councils,  Rangeland  Management  Program,
                  Bureau of Land Management" (No. 98-I-646)

Attached for your information is a copy of the subject final
advisory  report.  The report presented the  results  of our
review  of  the Resource Advisory Councils of the Bureau  of
Land  Management's   Rangeland   Management   Program.   The
original objective of the audit was to determine whether the
Bureau had effectively implemented land use decisions during
fiscal  years  1996,  1997,  and 1998 (through February)  to
improve rangeland conditions.  However, effective August 21,
1995, the Bureau revised its grazing  regulations to provide
fundamental standards and guidelines for assessing rangeland
health.   At  the  time  of the audit, these  standards  and
guidelines  had  not  been  implemented.    Accordingly,  we
deferred  our  audit  of  rangeland  conditions  until   the
standards and guidelines were fully implemented.  During the
entrance   conference   on  October  30,  1997,  the  Bureau
requested  that  we  revise  our  objective  to  review  the
effectiveness of the Resource  Advisory Councils, which were
established  to  assist the Bureau  in  developing  the  new
standards and guidelines  and in advising the Bureau on land
use policy issues.

We determined that, overall,  the Resource Advisory Councils
worked  effectively  with  the Bureau.   Specifically,  they
assisted  in  developing  standards   and   guidelines   for
rangeland  health,  represented  and reached consensus among
diverse  public  interest  groups, and  advised  the  Bureau
concerning land use decisions.   However, we also noted that
all Council members had not received  the  training required
by   the   Code   of   Federal  Regulations.   In  addition,
representatives from other  Federal  agencies  that had land
within  the authorized boundaries of the Councils  were  not
involved in the process except in Oregon/Washington, and the
Wyoming Council  had  not  been rechartered.  The report did
not contain any recommendations.

If  you have any questions concerning  this  matter,  please
contact  me  at  (202)  208-5745 or Mr.  Robert J. Williams,
Assistant Inspector General for Audits, at (202) 208-4252.


Attachment





ADVISORY REPORT                            C-IN-BLM-001-98D


Memorandum


     To:  Director, Bureau of Land Management

   From:  Robert J. Williams
          Assistant Inspector General for Audits

Subject:  Advisory Report on the Resource Advisory
          Councils, Rangeland Management Program, Bureau of
          Land Management (No. 98-I-646)


INTRODUCTION

This  report presents  the  results  of  our  audit  of  the
Resource   Advisory   Councils   of   the   Bureau  of  Land
Management's  Rangeland  Management  Program.  The  original
objective of the audit was to determine  whether  the Bureau
had effectively implemented land use decisions during fiscal
years  1996,  1997,  and  1998 (through February) to improve
rangeland conditions.  However,  effective  August 21, 1995,
the  Bureau  revised  its  grazing  regulations  to  provide
fundamental standards and guidelines for assessing rangeland
health.   At  the  time  of  the audit, these standards  and
guidelines  had  not  been  implemented.    Accordingly,  we
deferred  our  audit  of  rangeland  conditions  until   the
standards and guidelines were fully implemented.  During the
entrance   conference   on  October  30,  1997,  the  Bureau
requested  that  we  revise  our  objective  to  review  the
effectiveness of the Resource  Advisory  Councils,[1]  which
were established to assist the Bureau in developing the  new
standards  and guidelines and in advising the Bureau on land
use policy issues.

BACKGROUND

The Bureau of  Land  Management is responsible for managing,
protecting, and improving  about 260 million acres of public
land  in the western states,  including  about  166  million
acres  of  rangeland.   The  Bureau's  Rangeland  Management
Program  involves  managing  rangeland  ecosystems to ensure
their health, natural diversity, and long-term productivity.
Rangeland   management   activities   include  administering
livestock  grazing  permits,  supporting wildlife  habitats,
serving  wild  horse  and burro needs,  promoting  watershed
health,  and maintaining  and  improving  the  condition  of
rangelands  to  serve  a  variety  of  uses.  The rangelands
provide forage for about 3.7 million livestock  (cattle  and
sheep) and 42,000 wild horses and burros annually.

The  basic  authority  for  the  Bureau's  livestock grazing
program was established by the Taylor Grazing  Act  of 1934,
as   amended,   which  was  enacted,  in  part,  to  prevent
overgrazing and soil  deterioration on public rangelands and
to provide for the orderly use, improvement, and development
of  public  rangelands.    The   Federal   Land  Policy  and
Management  Act  of  1976  requires  the  Secretary  of  the
Interior to prepare and maintain an inventory  of all public
lands  and  their resources.  This inventory is to  be  kept
current to reflect  changes  in  conditions.   Further,  the
Public  Rangelands  Improvement  Act  of  1978  required the
Bureau  to  include the trend in rangeland condition  to  be
maintained as  part  of  the inventory of public lands.  The
Bureau based its early inventories  on  the amount of forage
that  was  available  to  sustain  livestock and  classified
rangelands as excellent, good, fair,  or  poor  according to
the available forage.  By 1980, the emphasis on inventorying
public  land  had shifted from a forage-based method  to  an
ecological-based   method.    As   such,   rangelands   were
reclassified  according  to  the  percentage of native plant
species,  or  the  potential  natural community,  that  each
rangeland  supported.  However,  the  forage-based  and  the
ecological-based  classifications  were  not  comparable,  a
condition  that impeded the Bureau's ability to complete the
inventory process  and  determine the trend in the condition
of public rangelands, as required by the Federal Land Policy
and  Management  Act  of  1976  and  the  Public  Rangelands
Improvement Act of 1978.    As  of  fiscal  year  1996,  the
Bureau  had inventoried 126 million of the 166 million acres
of public  rangelands,  consisting of 86 million acres using
ecological-based data and  40  million  acres  using forage-
based data.  Four of the 14 members of the National Research
Council's[2] Committee on Rangeland Classification  told  us
that  they  believed  the  Bureau  should continue to gather
ecological site data for the remaining  80  million acres of
public rangeland and use independent organizations that have
expertise in rangeland management to establish an acceptable
methodology for classifying the condition of the rangelands.
For   example,   in  1994,  the  National  Research  Council
published  "Rangeland   Health-New   Methods   to  Classify,
Inventory,  and Monitor Rangelands," which recommended  that
standardized   indicators   and   methods  for  inventorying
rangeland health be established.  The publication stated:

     An  agreed-to  standard  that  can   be   used  to
     determine whether the capacity of these rangelands
     to produce commodities and satisfy values is being
     conserved,  degraded, or improved is needed.   The
     lack  of  a  consistently   defined  standard  for
     acceptable conditions of rangeland  ecosystems  is
     the most significant limitation to current efforts
     to   assess  rangelands.   The  lack  of  such  an
     agreed-to  standard  has  and continues to confuse
     the public, the U.S. Congress, ranchers, and range
     scientists themselves.

Effective August 21, 1995, the Bureau  revised  its  grazing
regulations contained in the Code of Federal Regulations (43
CFR   1780   and  4100)  and  on  August  30,  1996,  issued
Instruction Memorandum  No.  96-172, "Implementing Standards
of Rangeland Health and Guidelines  for Grazing Management,"
to  implement the revised regulations.   Under  the  revised
regulations,  the  Bureau's State Directors, in consultation
with  Resource  Advisory   Councils,   are  responsible  for
developing  and  amending  state or regional  standards  and
guidelines to address the basic principles[3] needed to help
achieve healthy, sustainable  rangelands.   In addition, the
revised   regulations   included  "fallback  standards   and
guidelines" that should be  used  until  state  or  regional
standards and guidelines are completed.

The  revised  grazing  regulations also established Resource
Advisory  Councils  to  assist   the  Bureau  in  developing
rangeland standards, in preparing  and implementing land use
plans,  and  in  establishing  other  long-range  plans  and
management priorities.  The Council members are appointed by
the  Secretary  of  the  Interior, with membership  balanced
among   three   interest  groups:    commodity   industries,
recreational and  environmental  interests,  and  local area
interests.   All  members  of a Council are required by  the
Code (43 CFR 1780) to attend  a course of instruction in the
management of rangelands that has  been approved by a Bureau
State Director.  As of February 1998, there were 24 Resource
Advisory Councils representing 13 states (see the Appendix).

SCOPE

We  reviewed  the  activities  of the 24  Resource  Advisory
Councils in 13 states from their inception in September 1995
through February 1998 and of the  Wyoming  Resource Advisory
Council from inception to 1996, when it was not rechartered.
Our  review  included  attending a standards and  guidelines
implementation workshop  hosted  by  the  Bureau  in Denver,
Colorado,  and  Resource  Advisory  Council meetings in  Las
Vegas, Nevada, and Montrose, Colorado.   We also visited the
Bureau's  Nevada  State Office, Carson City  and  Winnemucca
field offices, and  its  National Business Center in Denver.
In addition, we reviewed the  Bureau's  "National  Rangeland
Inventory,  Monitoring  and Evaluation Report,  Fiscal  Year
1996" and the National Research Council's "Rangeland Health,
New Methods to Classify, Inventory, and Monitor Rangelands."
We  interviewed  88  Council   members,  including  original
members who had been reappointed,  and  new  members from 14
states, including Wyoming, to obtain their opinions  on  the
(1)  effectiveness  of  the  Resource Advisory Councils; (2)
representation  of  interest groups  on  the  Councils;  (3)
ability to reach consensus  on major land use policy issues;
and (4) cooperation of the Bureau, particularly the Bureau's
responsiveness to their concerns.   Further,  we interviewed
members of the  National Research Council and Bureau program
personnel  regarding  the effectiveness of the Councils.  We
also  viewed  an  interactive  satellite  broadcast  between
Resource Advisory Council  members  and the Secretary of the
Interior  in  conjunction with a Bureau  publication  titled
"Partners Across the West-Resource Advisory Councils."

Our audit was conducted  in  accordance with the "Government
Auditing Standards," issued by  the  Comptroller  General of
the  United States.  Accordingly, we included such tests  of
records  and  other auditing procedures that were considered
necessary under the circumstances.  As part of our audit, we
reviewed the Department  of  the  Interior's  Accountability
Report  for  fiscal  year  1996,  which includes information
required by the Federal Managers' Financial Integrity Act of
1982, and the Bureau's annual assurance statement for fiscal
year 1997 to determine whether any  reported weaknesses were
within the objective and scope of our review.  We found that
a material weakness was reported by the  Bureau  relating to
inadequate range monitoring data.  To resolve this weakness,
the   Bureau   issued  Instruction  Memorandum  No.  96-172,
"Implementing Standards   of Rangeland Health and Guidelines
for  Grazing  Management,"  and   conducted  a  workshop  on
implementation  of  the  new standards  and  guidelines  for
rangeland health.

PRIOR AUDIT COVERAGE

Neither  the Office of Inspector  General  nor  the  General
Accounting  Office  has  issued any audit reports during the
past 5 years on the Bureau's Rangeland Management Program.

                         DISCUSSION

We concluded that, overall,  the  Resource Advisory Councils
worked  effectively  with  the Bureau  of  Land  Management.
Specifically,  they assisted  in  developing  standards  and
guidelines for rangeland  health,  represented  and  reached
consensus  among diverse public interest groups, and advised
the Bureau concerning  land use decisions.  However, we also
noted that all Council members had not received the training
required by the Code of  Federal  Regulations (43 CFR 1780).
In  addition,  we  found  that  representatives  from  other
Federal  agencies  which  had  land  within  the  authorized
boundaries[4]  of  the  Councils were not  involved  in  the
process except in Oregon/Washington  and  that  the  Wyoming
Council had not been rechartered.

Standards

The  Code  of  Federal  Regulations  (43  CFR 1780 and 4100)
established   the  Resource  Advisory  Councils   with   the
objective of providing  advice  to  the  Department  and the
Bureau on formulating standards and guidelines and executing
plans  and  programs  for  the  use and management of public
lands.   Of  the 13 states that had  existing  Councils,  we
found that only  California  and  New  Mexico  did  not have
standards   approved  by  the  Secretary  of  the  Interior.
However, the  standards  for both states were being reviewed
by  the  Secretary,  and  the   Bureau  indicated  that  the
standards  should  be approved by the  end  of  1998.   Even
though each state developed its own standards and guidelines
for rangeland health,  we  believe  that  the  Bureau's  new
standards  and  guidelines  for  rangeland  health should be
reviewed  by the National Research Council to  independently
evaluate  the   effectiveness   of   these   standards   and
guidelines.   As such, we suggest that the Bureau coordinate
its efforts with  the National Research Council and the U.S.
Forest Service to develop, test, and establish indicators of
rangeland health that will be accepted on a national basis.

Consensus

The Code (43 CFR 1780)  requires the Councils to represent a
balance of diverse interest  groups concerned with rangeland
management  and  express  public  concerns  on  land  policy
issues.   A  primary  function   of  the  Resource  Advisory
Councils is to represent and reach  consensus  among diverse
interest  groups.  We concluded that the Councils  had  been
successful  in  achieving  this requirement, as shown in the
following examples:

     - For the past 2 years,  the  Alaska  Resource Advisory
Council has focused its efforts on conflicts  between  state
and  Federal  management  of  mining  activities  along  the
Fortymile  River,  which  is designated as a wild and scenic
river.  For example, the Council  worked with the Bureau and
the  State  of  Alaska to find a solution  involving  policy
interpretations that  allowed  miners  to camp while working
their claims rather than to propose changes  in  regulations
or in the wild and scenic river designation.

     - The   Dakotas   Resource   Advisory  Council  reached
consensus  on  a number of issues, including  rehabilitating
the Bear Butte Creek watershed in South Dakota; supporting a
land exchange between  the  Bureau  and  the  State of North
Dakota;  and supporting the completion of the Meridian  Oil,
Bureau, and  U.S.  Forest  Service mineral exchange in North
Dakota.

Land Use Decisions

The Code (43 CFR 1780) requires  the  Councils to advise the
Bureau on land use decisions.  We found  that the ability of
the  Resource  Advisory  Councils  to  reach  consensus  had
facilitated  the  Bureau's  ability to make land use  policy
decisions that protect the rangelands while making the lands
open to multiple use, as shown  in the following examples by
state:

     - The Arizona Resource Advisory  Group  is  helping the
Bureau   develop  the  Arizona  Recreation  Strategy.   This
strategy focuses  on  recreation  and tourism-related issues
and addresses issues affecting the  use  of public lands and
those  affecting  the  quality  of  life in the  communities
located near public land.

     - The   California  Desert  District   Advisory   Board
provided  advice   on   (1) implementation   of   wilderness
designations  resulting  from  the  1994  California  Desert
Protection  Act,  (2) establishment of recreation user fees,
(3) filming on public  lands, (4) management and use of off-
highway vehicles, (5) controversial  landfill  proposals  at
Eagle Mountain and Mesquite, (6) proposed mining operations,
and (7) problems associated with burros on public lands near
the Colorado River.

     - The  Colorado  Front  Range Resource Advisory Council
provided advice to the Bureau  on  issues, including grazing
trespass,  grazing standards and guideline   implementation,
and recreation  use.  The Council also assisted the Bureau's
Canon City District  in resolving a conflict with a business
involved  in  a  jointly   managed   recreation  area.   The
Southwest  Resource  Advisory Council recommended  that  the
Bureau  testify in support  of  proposed  legislation  which
would create  the  Black Canyon National Park Complex if the
legislation included  a  wilderness designation for Gunnison
Gorge.

     - After viewing the problem  areas within the watershed
and  visiting  with involved parties,  the  Upper  Columbia-
Salmon Clearwater  Advisory  Council made recommendations to
the Bureau that will help implement  the  Interior  Columbia
Basin Ecosystem Management Project.  In addition, the  Lower
Snake  River  Advisory  Council  has  provided advice to the
Bureau on issues related to a U.S. Air  Force  proposal  for
military  training  in  Idaho,  the  Bureau's Final Resource
Management Plan for the Owyhee Resource  Area  in Idaho, and
fire rehabilitation progress in the Boise Foothills.

The overall effectiveness of Resource Advisory Councils  was
further  illustrated  in  an interactive satellite broadcast
presented  by  the  Bureau on  February  20,  1998,  to  the
Resource Advisory Councils.   The  broadcast  entitled "RACs
[Resource  Advisory  Councils]:  Partners Across  the  West"
provided an opportunity  for  Council members to participate
in  an  exchange with the Secretary  of  the  Interior,  the
Assistant  Secretary  for  Land and Minerals Management, the
Bureau Director, and a panel  of  Council  members.   In the
presentation,  the  Secretary  of  the  Interior, in effect,
expanded  the role of the Councils by suggesting  that  they
also focus  on  solving  other  public  land issues, such as
implementing the Federal fire management  policy  adopted by
the   Departments   of  the  Interior  and  of  Agriculture,
combating invasive weeds,  applying standards and guidelines
to  other  resources  (such  as   watershed  and  recreation
management), and improving the land exchange process.

Training

The Code (43 CFR 1780) requires Council  members  to  attend
instructional training in management of rangelands that  has
been  approved  by  the  appropriate  Bureau State Director.
However,  we  found  that  new  Council  members   were  not
receiving  training on rangeland ecosystems, as required  by
the revised  grazing regulations.  Specifically, 7 of the 10
new members on  Colorado's two Councils had not received any
training on rangeland  ecosystems.  Additionally, at least 1
new  member  on  each of 11  other  Councils  also  had  not
received this training.  Bureau officials said that they did
not believe that new members needed the training because the
original  members  had  completed  the  development  of  the
standards  and  guidelines.   We  suggest  that  the  Bureau
provide training  on  rangeland  ecosystems  to  all Council
members because the Councils are still developing  standards
and guidelines for other resource areas.

Participation

The Code (43 CFR 1780) does not require representatives from
other  Federal agencies that have land within the boundaries
of the Councils  to  participate  with  the  Bureau  and the
Councils in land use decisions; however, the final rule  for
the Code states, "The RACs [Resource Advisory Councils] will
advise  the  Secretary and BLM [Bureau of Land Management] -
and other agencies  as  appropriate - on matters relating to
multiple  use  issues  associated   with  public  lands  and
resources."    We   believe   that  having  other   agencies
participate in the Council process  is  advantageous  to the
Bureau  and  the other agencies.  For example, we found that
in Oregon and  Washington, the U.S. Forest Service is a full
partner in the Council's  advisory  process.   The Southeast
Oregon Council's boundaries include all or portions of three
Bureau field offices and four National Forest Districts.  At
the  time  of  our  review,  the Council was addressing  the
issues of prescribed fires,[5]  water  quality,  and noxious
weeds[6]  for  both  agencies.   We  suggest that the Bureau
encourage participation from other Federal  agencies as part
of the Council's advisory process.

Wyoming Council

The  Code (43 CFR 1780) requires Councils to be  established
to improve  the  management  of public rangelands.  However,
the Wyoming Council has not been rechartered since 1996.  As
a  result, there is no forum available  for  the  public  to
participate  in the Bureau's land use policy decisions other
than  to respond  to  environmental  impact  statements  and
environmental  assessments,  which  require  notices  to  be
published  in  local  newspapers and the "Federal Register."
We  suggest  that  the  Bureau   increase   its  efforts  to
reestablish the Wyoming Council.

On  April  7, 1998, we held an exit conference  with  Bureau
officials.   In  general,  the  Bureau  concurred  with  the
results   of   our   audit.   Additionally,  we  provided  a
preliminary draft of this  report  to the Bureau on July 31,
1998.  The Bureau did not comment on  the preliminary draft.
Because this report does not contain any  recommendations, a
response is not required.

The   legislation,  as  amended,  creating  the  Office   of
Inspector  General  requires  semiannual  reporting  to  the
Congress  on  all  audit  reports  issued,  actions taken to
implement audit recommendations, and identification  of each
significant  recommendation  on which corrective action  has
not been taken.

We  appreciate the assistance of  Bureau  personnel  in  the
conduct of our review.


**FOOTNOTES**

[1]:The  Code  of Federal Regulations (43 CFR 1784) states that Resource
Advisory Councils  will  consist  of  members who have diverse interests
 that provide for public participation in  the  preparation and execution
of plans and programs for the management of public lands.

[2]:Members of the National Research Council are drawn from the Councils
of   the  National  Academy  of  Sciences,  the  National   Academy   of
Engineering, and the Institute of Medicine.

[3]:These  factors  are  watershed  health;  nutrient cycling and energy
flow;  water  quality;  habitat  for  endangered, threatened,  proposed,
candidate, or special status species; and  habitat  quality  for  native
plant and animal populations and communities.

[4]:Under the Code (43 CFR 1784.6-1), the Councils, as determined by the
Bureau  State  Director,  in  consultation  with  the Governor and other
interested  parties,  may  be  formed on the basis of state  boundaries,
Bureau districts, or "ecoregions."

[5]:As defined by the Society of  Rangeland Management, prescribed fires
(burning)  are  a management tool used  under  specific  conditions  for
burning a predetermined area.

[6]:As defined by  the  Society  of  Rangeland Management, noxious weeds
(species) are undesirable because they  conflict, restrict, or otherwise
cause problems under the management objectives.


                                                                APPENDIX


                  RESOURCE ADVISORY COUNCILS

              State Resource Advisory Councils[1]


Alaska                     Alaska Resource Advisory Council

Arizona                    Arizona Resource Advisory Council

California                 California Desert District Resource
Advisory Council[2]
                           Central California Resource Advisory
Council
                           Northeastern California Resource
Advisory Council
                           Northwestern California Resource
Advisory Council

Colorado                   Front Range Resource Advisory Council
                           Northwest Resource Advisory Council
                           Southwest Resource Advisory Council

                           Idaho Lower Snake River Resource
                           Advisory Council
                           Upper Snake River Resource Advisory
                           Council
                           Upper Columbia/Salmon Clearwater
                           Resource Advisory Council

Montana/North Dakota and   Butte Resource Advisory Council
South Dakota               Dakotas Resource Advisory Council
                           Lewistown Resource Advisory Council
                           Miles City Resource Advisory Council

                           Nevada   Mojave-Southern   Great  Basin
                           Resource Advisory Council
                           Northeastern   Great   Basin   Resource
                           Advisory Council
                           Sierra-Front  Northwestern Great  Basin
                           Resource Advisory          Council

New Mexico                 New Mexico Resource Advisory Council

Oregon/Washington          Eastern  Washington  Resource  Advisory
Council
                           John   Day-Snake    Resource   Advisory
Council
                           Southeast   Oregon  Resource   Advisory
Council

Utah                       Utah Resource Advisory Council

*FOOTNOTES**

[1]:The Wyoming Resource Advisory Council has not been rechartered since
the summer of 1996.

[2]:The  California Desert District Advisory  Council  was  specifically
required by  the  Federal Land Policy and Management Act of 1976 and was
established in 1980.










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