GAO/RCED-97-71

Forest Service Decision-Making:
A Framework for Improving Performance

Chapter Report, 04/29/97

 

Pursuant to congressional requests, GAO reviewed the Forest Service's decisionmaking process, focusing on: (1) the inadequate attention that the Forest Service has given to improving the process; (2) the lack of agreement, both inside and outside the agency, on how it is to resolve conflicts among competing uses on its lands; (3) unresolved interagency issues that transcend its administrative boundaries and jurisdiction; and (4) differences in the requirements of laws that help frame its decisionmaking.

GAO noted that: (1) some of the inefficiency in developing forest plans and reaching project-level decisions, as well as the ineffectiveness in achieving the plans' objectives, has occurred because the Forest Service has not given adequate attention to improving its decisionmaking process, including improving accountability for its performance; (2) as a result, the Forest Service: (a) must request more funds to accomplish fewer objectives during the yearly budget and appropriation process; and (b) has not corrected long-standing deficiencies within its decisionmaking process that have contributed to increased costs and time and/or the inability to achieve planned objectives; (3) strengthening accountability for performance within the Forest Service and improving the efficiency and effectiveness of its decisionmaking is contingent on establishing long-term strategic goals that are based on clearly defined mission priorities; (4) however, agreement does not exist on the agency's long-term strategic goals; (5) this lack of agreement is the result of a more fundamental disagreement, both inside and outside the Forest Service, over which uses the agency is to emphasize under its broad multiple-use and sustained-yield mandate and how best to ensure the long-term sustainability of these uses; (6) issues that transcend the agency's administrative boundaries and jurisdiction also affect the efficiency and effectiveness of the agency's decisionmaking; (7) in particular, the Forest Service has had difficulty reconciling the administrative boundaries of the national forests with the boundaries of natural systems, such as watersheds and vegetative and animal communities, both in planning and in assessing the effects of federal and nonfederal activities on the environment; (8) finally, the requirements of planning and environmental laws, enacted primarily during the 1960s and 1970s, have not been harmonized; (9) differences among the requirements of various laws and their differing judicial interpretations require some issues to be analyzed or reanalyzed at different stages in the Forest Service's decisionmaking process without any clear sequence leading to their timely resolution; (10) additional differences among the statutorily required approaches for protecting various resources have also sometimes been difficult to reconcile;

--------------------------- Indexing Terms -----------------------------
Land management National forests Agency missions Strategic planning Environmental law Land use law Forest management Accountability Interagency relations Wildlife conservation IDENTIFIER: Forest Service Timber Sales Program Black Hills National Forest (SD) Carson National Forest (NM) Eldorado National Forest (CA) Flathead National Forest (MT) Deschutes National Forest (OR) Mt. Hood National Forest (OR) Gifford Pinchot National Forest (WA) Ouachita National Forest (AR) Chattahoochee-Oconee National Forest (GA) Nantahala-Pisgah National Forest (NC) Forest Service Emergency Salvage Timber Sale Program Wenatchee National Forest (WA) Knutson-Vandenberg Trust Fund Salvage Sale Fund Columbia River Basin (WA) Boise National Forest (ID)

Forest Service Decision-Making (140541)

Abbreviations

CEQ - Council on Environmental Quality
EA - environmental assessment
EIS - environmental impact statement
EPA - Environmental Protection Agency
ESA - Endangered Species Act
FACA - Federal Advisory Committee Act
FWS - Fish and Wildlife Service FWS/NMFS -
GAO - General Accounting Office
GIS - geographic information system
GPRA - Government Performance and Results Act
NEPA - National Environmental Policy Act
NFMA - National Forest Management Act
NMFS - National Marine Fisheries Service
OTA - Office of Technology Assessment
RPA - Forest and Rangeland Renewable Resources Planning Act

B-276170

April 29, 1997

Congressional Requesters

As agreed with your offices, this report discusses the underlying causes of inefficiency and ineffectiveness in the decision-making process used by the Department of Agriculture's Forest Service in carrying out its mission. The report contains a matter for congressional consideration and recommendations to the Chair of the Council on Environmental Quality and to the Secretary of Agriculture designed to reduce the costs and time of the decision-making process and/or improve the agency's ability to deliver what is expected or promised.

We are sending copies of this report to the appropriate congressional committees, the Chair of the Council on Environmental Quality, the Secretary of Agriculture, and the Chief of the Forest Service. We will also make copies available to others upon request.

Major contributors to this report are listed in appendix VI.

Victor S. Rezendes
Director, Energy, Resources, and Science Issues

List of Requesters

The Honorable Frank H. Murkowski Chairman, Committee on Energy and Natural Resources United States Senate

The Honorable Larry Craig Chairman, Subcommittee on Forests and Public Land Management Committee on Energy and Natural Resources United States Senate

The Honorable James V. Hansen Chairman, Subcommittee on National Parks and Public Lands Committee on Resources House of Representatives

The Honorable Ralph Regula Chairman, Subcommittee on Interior and Related Agencies Committee on Appropriations House of Representatives

The Honorable Conrad Burns United States Senate

EXECUTIVE SUMMARY

PURPOSE

The decision-making process used by the Department of Agriculture's Forest Service in carrying out its mission is costly and time-consuming, and 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 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 new information and events, as well as changes in funding and natural conditions.

In response to congressional requests, GAO examined the Forest Service's decision-making process. In this report, GAO discusses the internal and external causes of inefficiency and ineffectiveness in the process: (1) the inadequate attention that the Forest Service has given to improving the process; (2) the lack of agreement, both inside and outside the agency, on how it is to resolve conflicts among competing uses on its lands; (3) unresolved interagency issues that transcend its administrative boundaries and jurisdiction; and (4) differences in the requirements of laws that help frame its decision-making.

BACKGROUND

The Forest Service manages about 192 million acres of land--nearly 9 percent of the nation's total surface area and about 30 percent of all federal lands. Laws guiding the management of the nation's 155 national forests require the agency to manage its lands under the principles of multiple use and sustained yield to meet the diverse needs of the American people.

Under the multiple-use principle, the Forest Service is required to plan for six renewable surface uses--outdoor recreation, rangeland, timber, watersheds and water flows, wilderness, and wildlife and fish. Under the sustained-yield principle, the agency is to manage its lands to provide high levels of all of these uses to current users while sustaining undiminished the lands' ability to produce these uses for future generations.

To carry out its mission, the Forest Service follows a decision-making process that includes (1) preparing a long-term strategic plan that maps the agency's course for the next decade and beyond, (2) developing regional guides that direct the management of its national forests, (3) developing plans for managing each forest, and (4) reaching project-level decisions for implementing these plans. In developing plans and reaching project-level decisions, the Forest Service must comply with the requirements of environmental statutes, including the National Environmental Policy Act, the Endangered Species Act, the Clean Water Act, and the Clean Air Act. The Council on Environmental Quality in the Executive Office of the President is responsible for issuing governmentwide regulations to implement the provisions of the National Environmental Policy Act. The responsibility for implementing and enforcing environmental laws and regulations is dispersed among several federal regulatory agencies, as well as state and local agencies.

RESULTS IN BRIEF

Some of the inefficiency in developing forest plans and reaching project-level decisions, as well as the ineffectiveness in achieving the plans' objectives, has occurred because the Forest Service has not given adequate attention to improving its decision-making process, including improving accountability for its performance. As a result, the Forest Service (1) must request more funds to accomplish fewer objectives during the yearly budget and appropriation process and (2) has not corrected long-standing deficiencies within its decision-making process that have contributed to increased costs and time and/or the inability to achieve planned objectives.

Strengthening accountability for performance within the Forest Service and improving the efficiency and effectiveness of its decision-making is contingent on establishing long-term strategic goals that are based on clearly defined mission priorities. However, agreement does not exist on the agency's long-term strategic goals. This lack of agreement is the result of a more fundamental disagreement, both inside and outside the Forest Service, over which uses the agency is to emphasize under its broad multiple-use and sustained-yield mandate and how best to ensure the long-term sustainability of these uses.

Issues that transcend the agency's administrative boundaries and jurisdiction also affect the efficiency and effectiveness of the agency's decision-making. In particular, the Forest Service has had difficulty reconciling the administrative boundaries of the national forests with the boundaries of natural systems, such as watersheds and vegetative and animal communities, both in planning and in assessing the effects of federal and nonfederal activities on the environment.

Finally, the requirements of planning and environmental laws, enacted primarily during the 1960s and 1970s, have not been harmonized. Differences among the requirements of various laws and their differing judicial interpretations require some issues to be analyzed or reanalyzed at different stages in the Forest Service's decision-making process without any clear sequence leading to their timely resolution. Additional differences among the statutorily required approaches for protecting various resources--such as endangered and threatened species, water, air, diverse plant and animal communities, and wilderness--have also sometimes been difficult to reconcile. However, GAO believes 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 the agency's mission priorities.

PRINCIPAL FINDINGS

THE FOREST SERVICE HAS NOT GIVEN ADEQUATE ATTENTION TO IMPROVING ITS DECISION-MAKING PROCESS

The Forest Service has not given adequate attention to reducing the costs and time of its decision-making and improving its ability to deliver what is expected or promised. As a result, the Forest Service must request more annual appropriations to achieve fewer planning objectives, and deficiencies within the decision-making process that have been known to the agency for a decade or more have not been corrected.

The Forest Service has made little progress in holding its managers accountable for their performance. For example, in response to congressional concerns about the Forest Service's inability 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 included (1) establishing work agreements that include measures and standards with customers' 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 planned to implement over the next decade.

Because the Forest Service has made little progress in holding managers accountable for their performance, it must request more funds to accomplish fewer objectives in forest plans 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 two major examinations of its timber program and is now preparing to undertake a third. 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 (6 percent) more for timber sale management than was appropriated for fiscal year 1997 while proposing to offer 0.4 billion board feet (10 percent) less timber for sale.

Another result of the lack of accountability within the Forest Service has been that long-standing deficiencies within the agency's decision-making process, which have driven up costs and time and/or driven down the ability to achieve planned objectives, have not been corrected. These deficiencies include (1) not adequately monitoring the effects of past management decisions to more accurately estimate the effects of similar future decisions and to modify decisions when new information is uncovered or when preexisting monitoring thresholds are crossed, (2) not maintaining comparable environmental and socioeconomic data that are useful and easily accessible to forest managers, and (3) not adequately involving the public at the beginning of the decision-making process when problems are identified, data are gathered, and relationships are established and maintaining their involvement throughout the process.

For example, adequate monitoring of the effects of past management decisions is critical to accurately estimate the environmental effects of similar future decisions. 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) generally does not monitor the implementation of its plans as its regulations require. The Forest Service's past failure to monitor represents a lost opportunity to reduce the costs and time of future decision-making.

AGREEMENT NEEDS TO BE REACHED ON HOW THE FOREST SERVICE SHOULD RESOLVE CONFLICTS AMONG COMPETING USES

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. It requires each federal agency to develop, no later than September 30, 1997, a strategic plan that covers a period of at least 5 years. The Forest Service is planning to prepare two long-term strategic plans--one to comply with the requirements of the Government Performance and Results Act and another that maps the agency's course for the next decade and beyond, as required by another statute.

Successful implementation of the requirements of the Government Performance and Results Act is contingent on establishing long-term strategic goals that are based on clearly defined mission priorities. However, agreement does not exist on the Forest Service's long-term strategic goals. This lack of agreement is the result of a more fundamental disagreement, both inside and outside the Forest Service, over which uses to emphasize under the agency's broad multiple-use and sustained-yield mandate and how best to ensure the long-term sustainability of these uses.

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. 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. When proposing a project, the Forest Service bears the burden of demonstrating 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 reduce its emphasis on consumption and increase its emphasis on conservation, the Congress has never explicitly accepted this shift in emphasis or acknowledged its effects on the availability of other uses on national forests. If the Forest Service is to be held accountable for its performance, the agency will need to consult with the Congress on its strategic long-term goals, as the Government Performance and Results Act requires. This process may entail identifying legislative changes that are needed to clarify or modify the Congress's intent and expectations.

Such a consultation would create an opportunity for the Forest Service to gain a clearer understanding of which uses to emphasize under its broad multiple-use and sustained-yield mandate and how to resolve conflicts or make choices among competing uses on its lands. This understanding would, in turn, provide the agency with a basis for establishing long-term strategic goals, as well as performance goals and measures that are linked to them.

INTERAGENCY ISSUES AFFECT THE FOREST SERVICE'S DECISION-MAKING

Issues that transcend the agency's administrative boundaries and jurisdiction also adversely affect the efficiency and effectiveness of the Forest Service's decision-making process. These issues include 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 effects of their actions on natural systems.

Because the boundaries of administrative units and natural systems are frequently different, 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, a recognized ecological system, contains 74 separate federal land units, including 35 national forests, each with its own management plan and information database. Not analyzing effects on natural systems and their components at the appropriate ecological scale can result in duplicative environmental analyses for individual plans and projects, increasing the costs and time required for analysis and reducing the effectiveness of federal land management decision-making.

Over the past few years, several major studies have examined the need to reconcile differences in the geographic areas that federal agencies must consider when reaching decisions. Among the options for reconciliation that have been suggested are changes to the Council on Environmental Quality's regulations and guidance for implementing the National Environmental Policy Act. Such changes include amending the Council's regulations to require that the environmental analysis accompanying a plan or project be "tiered," or linked, to a broader-scoped environmental study and that the analysis itself focus on the environmental issues specific to the plan or project. While tiering is currently allowed, it is not required.

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 interagency agreements. However, interagency agreements (1) have not been lived up to by agencies in the past, (2) are generally not enforceable by outside parties, and (3) do not provide a basis for common approaches among all agencies. Also, federal land management and regulatory agencies sometimes do not work efficiently and effectively together to address issues that transcend their boundaries and jurisdictions. In addition, the environmental and socioeconomic 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. Therefore, although strong leadership by the Council would help to ensure that interagency agreements accomplish their intended objectives, the Council may also need to consider changes to its regulations and guidance for implementing the National Environmental Policy Act.

DIFFERENCES IN THE REQUIREMENTS OF LAWS AFFECT THE FOREST SERVICE'S DECISION-MAKING

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. Requirements to consider new information and events and 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, increasing the costs and time of decision-making and reducing the agencies' ability to achieve the objectives in their plans.

For instance, the listing of a species as endangered or threatened under the Endangered Species Act after a forest plan has been approved can require the Forest Service to reinitiate formal consultations with federal regulatory agencies to amend or revise the plan. The listing may also prohibit the Forest Service from implementing projects under the plans that may affect the species until the new round of consultations has been completed. Recent federal court decisions have required the Forest Service to reinitiate consultations on several approved forest plans. For example, 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 ruled that the agency could not implement projects under the plans that might affect the species until the new rounds of consultations had been completed.

Differing judicial interpretations of the same statutory requirements have also established conflicting requirements. For instance, 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.

In addition, differences between environmental laws and agencies' planning statutes can be difficult to reconcile. Whereas environmental laws typically address individual resources--such as endangered and threatened species, water, and air--the Forest Service's and other federal land management agencies' 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 Forest Service's planning statutes but may be difficult to reconcile in the short term with air and water quality standards under the Clean Air and Clean Water acts.

Adequately addressing the differences in the requirements of laws affecting the Forest Service's decision-making would require a systematic and comprehensive analysis of the laws to avoid making changes that would entail unintended consequences for the future. GAO has observed that the Forest Service's decision-making process is clearly broken and in need of repair. Moreover, to improve the efficiency and effectiveness of the process, a consensus for statutory changes appears to be growing. However, any legislation that may be needed to clarify or modify the Congress's intent and expectations requires that the Forest Service and the Congress reach agreement on the agency's long-term strategic goals, on the uses that the agency should emphasize under its broad multiple-use and sustained-yield mandate, and on the steps that the agency should take to resolve conflicts or make choices among competing uses on its lands.

Without agreement on the Forest Service's mission priorities, GAO sees distrust and gridlock prevailing in any effort to streamline the agency's statutory framework. For instance, during his Senate confirmation hearing in April 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, the Secretary has not sent to the Congress either his analysis or the options for changing the current statutory framework suggested by the Forest Service in 1995. 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.

MATTER FOR CONGRESSIONAL CONSIDERATION

The Congress may wish to consider how the requirements of the Government Performance and Results Act can be integrated most efficiently into the Forest Service's current decision-making process. Specifically, the Congress may wish to consider eliminating the requirement in the Forest Service's statutory framework that the agency develop a strategic plan for the next decade or more when it is also required to develop a similar strategic plan under the Government Performance and Results Act.

RECOMMENDATION TO THE SECRETARY OF AGRICULTURE

GAO recommends that the Secretary of Agriculture direct the Chief of the Forest Service to identify how the agency will link a long-term strategic goal with annual performance goals and measures.

RECOMMENDATIONS TO THE CHAIR OF THE COUNCIL ON ENVIRONMENTAL QUALITY

GAO recommends that the Chair of the Council on Environmental Quality change the Council's regulations for implementing the National Environmental Policy Act to require, rather than merely allow, federal agencies to tier plans and projects to broader-scoped studies. In addition, GAO recommends that the Chair revise the Council's regulations and guidance for implementing the act to improve interagency coordination; identify a baseline of comparable environmental data needed for agencies to implement the act; and assume or assign responsibility for collecting, managing, and making the data available to other users. GAO is not recommending precise changes to the Council's regulations or guidance because GAO believes that such changes are better left for the Council to determine on the basis of its own internal study and its evaluation of the outside views solicited during its effort to reinvent federal agencies' implementation of the National Environmental Policy Act.

AGENCY COMMENTS AND GAO'S EVALUATION

GAO requested and received written comments on a draft of this report from the Forest Service and the Council on Environmental Quality. The Forest Service said that it agreed with many of the report's goals and identified actions that it is taking to clarify its long-term strategic goals, improve its accountability, and streamline its administrative processes and decision-making. Similarly, the Council agreed with the goals for implementing the National Environmental Policy Act articulated in the report but said it was using different mechanisms to achieve these goals.

The Forest Service said that it intends to establish strategic goals and related performance measures for managers, as well as work in partnership with other agencies more closely and issue revised regulations for implementing the National Forest Management Act. GAO believes that implementing these actions would improve the efficiency and effectiveness of the agency's decision-making process. However, as the report notes, while the Forest Service can and does identify problems, according to the agency's own analysis, without external attention it often fails to take corrective action. In its comments, the agency did not discuss either a schedule to implement the improvements or a plan to closely monitor its progress and periodically report on its performance, both of which GAO believes are needed to break the cycle of studying and restudying issues without any accountability or clear sequence for resolving them. The Forest Service did not comment on GAO's recommendation to the Secretary of Agriculture.

The Council on Environmental Quality identified actions that it is taking to reinvent the implementation of the National Environmental Policy Act on an agency-by-agency as well as on a more generic basis. These actions include streamlining procedures at individual agencies and examining issues on a sector-by-sector basis (e.g., timber, grazing, and oil and gas). GAO agrees with the Council that (1) differences among the cultures, organizations, and institutional goals of various federal agencies, as well as the substantive nature of their underlying missions, require the Council's regulations implementing the act to be generic in nature and (2) regulatory changes often need to be tailored specifically to individual agencies' processes. However, as this report indicates, some decision-making issues transcend federal agencies' administrative boundaries and jurisdictions, and for some of these issues, changes in the Council's regulations and guidance need to be considered. The Council did not agree with GAO's recommendation that it should change its guidance and regulations. However, GAO's recommendation to the Council's Chair is intended to ensure that the Council's planned multiyear reinvention effort does not prematurely or arbitrarily close off options for implementing the act more efficiently and effectively. GAO also clarified this recommendation to indicate that it is not recommending precise changes to the Council's regulations or guidance because, in its view, such changes can be best determined by the Council. On the basis of the agencies' comments, GAO revised the draft report where appropriate. The agencies' comments, together with GAO's responses to them, are presented fully in appendixes IV and V.

INTRODUCTION

In carrying out its mission, the Department of Agriculture's Forest Service follows a decision-making process that is largely based on planning laws enacted during the 1970s. This process includes (1) preparing a long-term strategic plan that maps the agency's course for the next decade and beyond, (2) developing regional guides that direct the management of its 155 national forests, (3) developing plans for managing each forest, and (4) reaching project-level decisions for implementing these plans.\1

Environmental laws, enacted primarily during the 1960s and 1970s, hold the Forest Service accountable for the ecological consequences of its decisions by requiring the agency to protect natural resources such as threatened and endangered species, wetlands, air, water, and wilderness.

\1 The Forest Service's decision-making process is explained in detail in app. I.

THE FOREST SERVICE'S MANAGEMENT IS DECENTRALIZED

The Forest Service, created in 1905, is a hierarchical organization whose management is highly decentralized. The Chief of the Forest Service heads the agency and, through Agriculture's Under Secretary for Natural Resources and Environment, reports to the Secretary of Agriculture. Under the Chief, there are an associate chief and six deputy chiefs, including one responsible for the National Forest System. In fiscal year 1995, the Forest Service received $3.4 billion in appropriated funds, of which about $1.3 billion, or about 38 percent, was allocated to the National Forest System. The National Forest System received another $1.2 billion in fiscal year 1995 from other sources--including moneys from trust funds and for fighting forest fires and fire protection, as well as credits for roads built by purchasers of timber sales, according to the Forest Service. As a result, funding for the National Forest System totaled over $2.5 billion. The system employs about 70 percent of the agency's approximately 36,000 personnel.

Forest Service headquarters (Washington Office) primarily establishes policy and provides technical direction to the agency's three levels of field management--9 regional offices, 123 forest offices, and about 600 district offices. At the Washington Office, the National Forest System has separate program directors for six different resources: heritage and wilderness, range, recreation, timber, watershed and air, and wildlife and fisheries. There is also a program director for planning. Similar lines of resource management exist at the regional, forest, and district office levels. However, because of budgetary constraints, the management of some resources may be combined.

The nine regional offices, each managed by a regional forester, interpret policy and provide additional direction to the 123 forest offices that manage the 155 national forests. Together, the Chief, the associate chief, the six deputy chiefs, the seven program directors, and the nine regional foresters make up the Forest Service's leadership team.

The forests, together with 20 national grasslands and 17 national recreation areas, make up the National Forest System. The forest offices, each managed by a forest supervisor, in turn, oversee the about 600 district offices, most of which are managed by a district ranger. The forest supervisors are primarily responsible for developing and implementing management plans for their respective forest(s) which are approved by the appropriate regional forester. The district rangers are primarily responsible for implementing project-level decisions within their respective district. At each level, managers have considerable autonomy and discretion for interpreting and applying the agency's policies and directions, guided by a system of manuals and handbooks keyed to statutes and regulations.

NATIONAL FORESTS ARE MANAGED UNDER THE PRINCIPLES OF MULTIPLE USE AND SUSTAINED YIELD

The Forest Service's motto is "caring for the land and serving people." Laws guiding the management of the National Forest System require the Forest Service to manage its lands under the principles of multiple use and sustained yield to meet the diverse needs of the American people. The agency is required to plan for six renewable surface uses only--outdoor recreation, rangeland, timber, watersheds and water flows, wilderness, and wildlife and fish. In addition, the Forest Service's guidance and regulations require that nonrenewable subsurface resources--such as oil, gas, and hardrock minerals--also be considered in preparing forest plans.\2

Under the Organic Administration Act of 1897, the national forests are to be established to improve and protect the forests within their boundaries or to secure favorable water flow conditions and provide a continuous supply of timber to citizens. The Multiple-Use Sustained-Yield Act of 1960 added the uses of outdoor recreation, range, watershed, and fish and wildlife. This act also requires the agency to manage its lands to provide high levels of all of these uses to current users while sustaining undiminished the lands' ability to produce these uses for future generations (the sustained-yield principle). Under the National Forest Management Act of 1976 (NFMA) and its implementing regulations, the Forest Service is to (1) recognize wilderness as a use of the forests and (2) maintain the diversity of plant and animal communities (biological diversity).

\2 Federal Land Management: Better Oil and Gas Information Needed to Support Land Use Decisions (GAO/RCED-90-71, June 27, 1990).

THE FOREST SERVICE IS PART OF A LARGER FEDERAL LAND MANAGEMENT ORGANIZATIONAL STRUCTURE

The federal government owns about 30 percent (about 650 million acres) of the nation's total surface area. The Forest Service, in turn, manages about 192 million acres of land, or about 30 percent of all federal lands. Forest Service lands include about one-fifth of the nation's forest lands.

The Forest Service is one of four major federal land management agencies. The other three are the National Park Service, the Bureau of Land Management, and the Fish and Wildlife Service, all within the Department of the Interior. Together, the four agencies manage about 95 percent of all federal lands.

The Fish and Wildlife Service manages a loosely structured system of about 500 wildlife refuges encompassing about 89 million acres. These refuges are concentrated in Alaska and along four major north-south waterfowl migration flyways. The agency manages its lands primarily to conserve and protect fish and wildlife and their habitat, although other uses--such as recreation (including hunting and fishing), mining and mineral leasing, livestock grazing, and timber harvesting--are allowed when they are compatible with the primary purposes for which the lands are managed.

The National Park Service manages about 77 million acres, divided into 374 national parks and other units in 49 states. The agency manages its lands to conserve, preserve, protect, and interpret the nation's natural, cultural, and historic resources for the enjoyment and recreation of current and future generations.

The Bureau of Land Management manages about 270 million acres, divided into resource areas and located mainly in the West and in Alaska. The Federal Land Policy and Management Act of 1976 requires the Bureau to manage its lands for multiple uses and sustained yield. The act defines multiple uses as recreation; range; timber; minerals; watershed; fish and wildlife; and natural, scenic, scientific, and historic values.

FEDERAL LAND MANAGEMENT AGENCIES MUST COMPLY WITH ENVIRONMENTAL LAWS AND REGULATIONS

All four of the major federal land management agencies must comply with the requirements of the National Environmental Policy Act of 1969 (NEPA). NEPA and its implementing regulations specify the procedures for integrating environmental considerations through environmental analyses and for incorporating public input into the agencies' decision-making processes. NEPA requires that a federal agency prepare a detailed environmental impact statement (EIS) for every major federal action that may significantly affect the quality of the human environment. The EIS is designed to ensure that important effects on the environment will not be overlooked or understated before the government makes a commitment to a proposed action.

In developing plans and reaching project-level decisions, the four agencies must also comply with the requirements of other environmental statutes, including the Endangered Species Act, the Clean Water Act, the Clean Air Act, the Wilderness Act, and the Migratory Bird Treaty Act, as well as other laws, such as the National Historic Preservation Act. The Forest Service is subject to more than 200 laws affecting its activities and programs.

NEPA established the Council on Environmental Quality (CEQ) within the Executive Office of the President. CEQ issued governmentwide regulations to implement the provisions of NEPA in 1978. CEQ also assists federal departments and agencies in coordinating programs and activities that affect, protect, or improve environmental quality. The responsibility for implementing and enforcing environmental laws and regulations is dispersed among several federal regulatory agencies, as well as state and local agencies. For example, the Fish and Wildlife Service and the Department of Commerce's National Marine Fisheries Service share the responsibility for ensuring the protection and recovery of threatened or endangered plant and animal species under the Endangered Species Act. The Environmental Protection Agency (EPA) has authorities and responsibilities to implement major environmental statutes, including those to protect and enhance air quality (the Clean Air Act) and to restore and maintain the chemical, physical, and biological integrity of the nation's waters (the Clean Water Act). The U.S. Army Corps of Engineers has authority under the Clean Water Act to regulate activities in wetlands and other waters of the United States.

THE FOREST SERVICE MUST INVOLVE THE PUBLIC IN ITS DECISION-MAKING

Both NEPA and NFMA and their implementing regulations require the Forest Service to involve the public in its decision-making process. In addition, NFMA requires the Secretary of Agriculture to establish and consult with advisory committees under the Federal Advisory Committee Act (FACA), as amended, if they are deemed "necessary to secure full information and advice." Passed in 1972, FACA was enacted to control the advisory committee process and to open to public scrutiny the manner in which government agencies obtain advice from private individuals and groups. FACA applies to formally organized committees or similar groups that the President or an executive department or official directs to provide advice or make recommendations. An advisory committee chartered under FACA must take a number of steps to ensure open public meetings. These steps include publishing timely notice of meetings in the Federal Register, holding meetings in public, making detailed minutes of the meetings available to the public, and allowing interested persons to appear before the committee.

OBJECTIVES, SCOPE, AND METHODOLOGY

Concerned about the costs, time, and complexity of the Forest Service's decision-making (see ch. 2), the Chairmen of the Senate Committee on Energy and Natural Resources and its Subcommittee on Forests and Public Land Management; the Chairman of the Subcommittee on National Parks, Forests, and Lands, House Committee on Resources;\3 the Chairman of the Subcommittee on Interior, House Committee on Appropriations; and Senator Conrad Burns asked us to identify and examine the decision-making process used by the Forest Service in carrying out its mission. (See app. I.) They have also asked us to testify on issues and options relating to the process.\4

In this report, we discuss the internal and external causes of inefficiency and ineffectiveness in the Forest Service's decision-making process: (1) the inadequate attention that the Forest Service has given to improving the process; (2) the lack of agreement, both inside and outside the agency, on how it is to resolve conflicts among competing uses on its lands; (3) unresolved interagency issues that transcend the Forest Service's administrative boundaries and jurisdiction; and (4) differences in the requirements of laws that help frame its decision-making. As agreed with the requesters' offices, we focused our work primarily on the relationship between the agency's timber production and other uses on the national forests.

To identify the decision-making process used by the Forest Service in carrying out its mission, we reviewed applicable laws and their legislative histories, regulations implementing the laws, executive orders, agency directives, and court cases. We also met with Forest Service headquarters and field managers and staff, headquarters and regional attorneys from Agriculture's Office of the General Counsel, and staff and counsel from CEQ.

To identify issues relating to the Forest Service's decision-making process and options to address them, we met with and reviewed documents provided by (1) officials in the Office of the Secretary of Agriculture and (2) the Chief of the Forest Service and other Forest Service headquarters and field personnel. During the course of our review, we visited 14 forests and one forest experiment station in 8 regions. We met with managers and staff from these units and from 24 ranger districts located on the forests that we visited. (See app. II for a list of these regions, forests, and ranger districts.) We also met with or contacted, and obtained documents from, headquarters and field managers and staff in EPA; Interior's Bureau of Land Management, National Park Service, and Fish and Wildlife Service; and Commerce's National Marine Fisheries Service.

We met with or contacted, and reviewed documents provided by, national and local officials and staff of professional forestry, timber and livestock industry, environmental, and recreational organizations, as well as academic and other natural resource policy analysts and officials from state and local governments and Native American tribes. (See app. III for the organizations contacted during this review.) In addition, we conducted a literature search and reviewed recent books and professional and scientific journal articles on federal land management.

We reviewed program and budget data for the Forest Service since its creation in 1905. We concentrated on the period since 1960, when the Multiple-Use Sustained-Yield Act was enacted, and especially on the period since 1976, when the National Forest Management Act was passed.

We also reviewed studies and reports prepared by the Forest Service and others, as well as legislation being considered by the Congress. We identified "best practices" evolving within the Forest Service that could improve efficiency or effectiveness if implemented agencywide. In addition, we attended various forums, conferences, workshops, and interagency meetings at which issues and options relating to the Forest Service's decision-making were discussed.

We performed our work primarily from August 1995 through March 1997 in accordance with generally accepted government auditing standards. In conducting our work, we did not independently verify or test the reliability of the data provided by the Forest Service or others. We obtained comments on a draft of this report from the Forest Service and CEQ. These agencies' comments and our responses are presented in appendixes IV and V.

\3 In the 105th Congress, this Subcommittee was split into a Subcommittee on Forests and Forest Health and a Subcommittee on National Parks and Public Lands.

\4 Forest Service: Issues Relating to Its Decisionmaking Process (GAO/T-RCED-96-66, Jan. 25, 1996), Forest Service: Issues Related to Managing National Forests for Multiple Uses (GAO/T-RCED-96-111, Mar. 26, 1996), and Forest Service Decision-Making: Greater Clarity Needed on Mission Priorities (GAO/T-RCED-97-81, Feb. 25, 1997).