GAO

United States General Accounting Office

Report to Congressional Requesters

September 2000 FOREST SERVICE

Proposed Regulations 

Adequately Address 

Some, but Not All, Key 

Elements of Forest 

Planning

GAO/RCED-00-256

Page 1 GAORCED-00-256 Forest Service

United States General Accounting Office

Washington, D.C. 20548

Resources, Community, and

Economic Development Division

B-285339 Letr

September 29, 2000 

The Honorable Larry E. Craig

Chairman, Subcommittee on Forests and

 Public Land Management

Committee on Energy and Natural Resources

United States Senate

The Honorable Helen Chenoweth-Hage

Chairman, Subcommittee on Forests 

 and Forest Health

Committee on Resources

House of Representatives

Since 1976, the Department of Agriculture’s Forest Service has been 

required by law to develop a land and resource management plan—

commonly called a forest plan—for each national forest or for groups of 

forests. A forest plan, among other things, spells out how the agency 

intends to (1) protect the lands and resources that it manages and (2) 

provide goods and services to the public. Each forest plan must be revised 

at least once every 15 years. From 1979 through 1995, the Forest Service 

spent over $250 million to develop 123 forest plans covering the 155 forests 

in the National Forest System. The agency now plans to spend about $375 

million to revise these forest plans and must complete revisions for nearly 

three-quarters of the plans in the next 5 years.

The current process used by the Forest Service to develop and revise forest 

plans has proven to be costly and time-consuming. National forests spend 

tens of millions of dollars a year attempting to develop forest plans that are 

legally defensible, scientifically credible, and able to sustain the forests’ 

resources. Yet, despite these efforts, the agency has often failed to achieve 

planned objectives.
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The Forest Service’s planning regulations set forth a process for 

developing, approving, amending, and revising forest plans. The existing 

planning regulations, approved in 1982,1

 have been under revision since 

March 1989,2

 when the agency initiated a comprehensive review of its 

planning process. In April 1995, the Forest Service proposed new planning 

regulations.3

 These regulations were based, in part, on the lessons learned 

by over 2,000 people who had participated in or had responsibilities for 

forest planning. However, the 1995 proposed planning regulations were 

never finalized. The effort to develop new planning regulations began again 

in 1997 when the Secretary of Agriculture convened a 13-member 

“Committee of Scientists” to take a fresh look at the Forest Service’s 

planning process and to offer recommendations for improvements. 

Primarily on the basis of the Committee’s findings, the Forest Service 

proposed new planning regulations in October 1999.4

 The public comment 

period ran from October 1999 through February 2000. The Forest Service 

expects to finalize the new planning regulations early in fiscal year 2001. 

Over the last 6 years, we have issued over 2 dozen products that have 

identified reasons for—and that have included recommendations to 

improve—the cost-effectiveness and timeliness of the Forest Service’s 

planning process.5

 Concerned about the outcome of the required forest 

plan revisions, you asked for our observations on the extent to which the 

agency’s proposed planning regulations address our prior findings, 

conclusions, and recommendations. In this report, we discuss the extent to 

which the Forest Service’s proposed planning regulations (1) make clear 

the agency’s mission priorities before beginning the process of revising a 

forest plan; (2) link forest plans to agencywide goals, objectives, and 

strategies; and (3) hold the forests more accountable for key elements of 

forest planning. 

1

47 Fed. Reg. 43026 (Sept. 30, 1982).

2

Synthesis of the Critique of Land Management Planning, Vol. 1, Forest Service (FS-452, June 

1990).

3

60 Fed. Reg. 18886 (Apr. 13, 1995).

4

64 Fed. Reg. 54074 (Oct. 5, 1999).

5

See the related products page at the end of this report for a list of GAO reports and 

testimonies on the Forest Service’s planning process.
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Results in Brief Federal land management is inherently contentious. Our work has found 

that a lack of clear direction on how to resolve conflicts among competing 

uses on national forest lands has contributed significantly to inefficiency 

and waste in the Forest Service’s development and implementation of 

forest plans. To address this deficiency, the agency’s 1999 proposed 

planning regulations would make ecological sustainability, rather than 

economic or social sustainability, the agency’s top priority, in order to 

provide a sustainable flow of products, services, and other values from 

national forests, consistent with laws and regulations guiding their use. 

Elevating the maintenance or restoration of ecological systems over other 

uses on the national forests is consistent with the agency’s evolving 

mission, which now favors resource protection over production. However, 

the priority assigned to ecological sustainability is not driven by the 

statutory authorities specific to the management of the national forests. 

Rather, it has evolved over many years, responding, in part, to the 

requirements in environmental laws—enacted primarily during the 1960s 

and 1970s—and their implementing regulations and judicial 

interpretations. As a result, the Congress has never explicitly accepted 

ecological sustainability as the Forest Service’s highest priority or 

acknowledged its effects on the availability of timber, recreation, and other 

goods and services on the national forests. We recommend that the Forest 

Service work with the Congress to reach agreement on the agency’s 

mission priorities. Responding to a draft of this report, the Forest Service 

stated that ecological sustainability is absolutely necessary to achieve 

other uses on the national forests. However, we believe that until the 

Congress and the agency reach agreement on ecological sustainability as 

the Forest Service’s highest priority, holding the agency accountable for its 

performance will be difficult.

In our previous work, we found that the Forest Service has made some 

progress in developing goals, objectives, and strategies that help translate 

its priorities into on-the-ground projects and activities. For example, the 

agency is refining its goals and objectives to better focus on outcomes and 

results to be achieved over time. It is also developing a strategy to reduce 

the incidence of uncontrollable and often catastrophic wildfires. Yet, even 

though many of these goals, objectives, and strategies are to be 

implemented through on-the-ground projects and activities governed by 

individual forest plans, the agency’s proposed planning regulations do not 

require that these forest plans be clearly linked to the goals, objectives, and 

strategies. We recommend that the Forest Service revise its proposed 

planning regulations to require the national forests to clearly link their 
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plans to the agency’s goals, objectives, and strategies and to blend them 

with local priorities in revising the plans. According to the Forest Service, 

its proposed regulations provide that there be a “direct link” between forest 

plans and national strategic goals and objectives. However, the proposed 

regulations merely require that long-term strategic goals, objectives, and 

outcome measures be “considered” in managing the national forests, not 

that they be clearly linked to the agency’s strategic plan. 

We previously found that in developing and implementing forest plans, 

national forests have not always (1) based their decisions on accurate and 

complete data; (2) adequately involved the public and other government 

agencies throughout the forest planning process; or (3) lived up to 

monitoring requirements, particularly those for monitoring the effects of 

past planing decisions. This has resulted in legal challenges to the plans 

and limited the implementation of efforts to expedite the planning process. 

To hold the forests more accountable for basing their decisions on accurate 

and complete data, we previously recommended that the agency revise its 

proposed planning regulations to require the national forests to develop 

strategies for gathering and incorporating data into their planning 

processes. The Forest Service agreed with the desired outcome of our 

previous recommendation but declined to revise the planning regulations, 

opting instead to revise its system of directives that implement the planning 

regulations. While we still believe that it would be preferable to place 

requirements in the agency’s planning regulations to develop strategies to 

help hold forests more accountable not only for gathering and 

incorporating data into their planning processes but also for involving the 

public and others in the planning processes and for monitoring and 

evaluating their decisions, we believe that the Forest Service should, at a 

minimum, revise its system of directives to require the national forests to 

(1) develop strategies for involving the public and other government 

agencies in their planning processes and for monitoring and evaluating 

their management decisions and (2) make the strategies available to the 

public. Accordingly, we are recommending that it take these actions. 
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Background The Forest Service, created in 1905, is required to manage its lands to 

provide for the sustained yield of six renewable surface uses—outdoor 

recreation, rangeland, timber, watersheds and waterflows, wilderness, and 

wildlife and fish. In addition, the agency is required by its guidance and 

regulations to consider the production of nonrenewable subsurface 

resources, such as oil, gas, and hardrock minerals,6

 in its planning. 

The Forest Service is a hierarchical organization whose management is 

highly decentralized and whose regional foresters and forest supervisors 

have considerable autonomy and discretion in interpreting and applying 

the agency’s policies and directions, guided by a system of directives 

consisting of manuals and handbooks keyed to statutes and regulations. 

The agency has three levels of field management—9 regional offices, 115 

forest offices, and about 600 district offices. Regional offices, each 

managed by a regional forester, interpret policy and provide additional 

direction to the 115 forest offices that manage the 155 national forests. The 

forest offices, each managed by a forest supervisor, in turn, oversee some 

600 district offices, most of which are managed by a district ranger. The 

forest supervisors are primarily responsible for developing and 

implementing forest plans for their respective forests. The district rangers 

are primarily responsible for implementing project-level decisions—“on the 

ground activities,” such as harvesting timber, restoring species’ habitats, 

and constructing campsites—within their respective districts. 

The Proposed 

Regulations Would 

Establish Ecological 

Sustainability as the 

Forest Service’s 

Overriding Mission 

Priority

One of the primary reasons for inefficiency and waste in developing and 

implementing forest plans is the lack of agreement on the Forest Service’s 

mission priorities. Federal land management is inherently contentious, and 

parties dissatisfied with a forest plan can cause a forest to delay, alter, or 

withdraw projects and activities that implement the plan by availing 

themselves of the opportunities for administrative appeal and judicial 

review that are provided by statute or regulation. To better avoid or prevail 

against legal challenges and to expedite the forest planning process, we 

have concluded that the Forest Service must provide the national forests 

with clear direction on how to resolve conflicts among competing uses 

when developing and implementing forest plans. Toward this end, the 

agency’s 1999 proposed planning regulations would make ecological 

sustainability, rather than economic or social sustainability, the agency’s 

6

Hardrock minerals include gold, silver, lead, iron, and copper.
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top priority, in order to provide a sustainable flow of products, services, 

and other values from national forests, consistent with laws and 

regulations guiding their use. 

Elevating the maintenance or restoration of ecological systems over other 

uses on the national forests is consistent with the agency’s evolving 

mission, which now favors resource protection over production. From 

1979, when the first forest plan was approved, through the late 1980s, the 

agency emphasized timber production over other uses on the national 

forests. Hence, the national forests emphasized timber production in many 

of their forest plans. However, the Forest Service has shifted its mission 

priorities away from producing timber and other commodities toward 

maintaining or restoring land health and forest resources. For example, the 

Forest Service’s fiscal year 2001 budget justification, submitted to the 

Congress in February 2000, states that “land health is the agency’s highest 

priority” and that the proposed budget would allow the Forest Service to 

accomplish its “conservation mission.”7

Although the Forest Service’s 1999 proposed planning regulations would 

make ecological sustainability, rather than economic or social 

sustainability, the agency’s top priority, the priority assigned to ecological 

sustainability is not driven by the statutory authorities specific to the 

management of the national forests. These authorities provide little 

direction for the agency in resolving conflicts among competing uses on its 

lands. Rather, the priority assigned to ecological sustainability is predicated 

on the requirements in environmental laws—enacted primarily during the 

1960s and 1970s—and their implementing regulations and judicial 

interpretations. These laws reflect changing public values and concerns 

about the management of the national forests as well as increased scientific 

understanding of the functioning of ecological systems and their 

components. 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 other missions of the Forest Service and 

other federal agencies.8

Because the priority assigned to ecological sustainability has evolved over 

many years, responding, in part, to many laws and judicial decisions, the 

7

FY 2001 Budget Justification, U.S. Department of Agriculture, Forest Service.

8

TVA v. Hill, 437 U.S. 153,185 (1978).
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Congress has never explicitly accepted it as the Forest Service’s highest 

priority or acknowledged its effects on the availability of timber, 

recreation, and other goods and services on the national forests. However, 

in 1999, the Chairman of the Subcommittee on Forests and Public Land 

Management, Senate Committee on Energy and Natural Resources, 

introduced S. 1320—the Public Lands Planning and Management 

Improvement Act of 1999. The bill appears to establish a starting point for 

the Congress and the administration to agree on the agency’s mission 

priorities. The bill’s mission statement would make clear that the Forest 

Service’s overriding mission priority is ecosystem sustainability and 

acknowledges the effects of sustaining ecosystems on the availability of 

other uses on the national forests.

The Proposed 

Regulations Would Not 

Require That Forest 

Plans Be Clearly 

Linked to Strategic 

Goals, Objectives, and 

Strategies 

The Government Performance and Results Act of 1993 (the Results Act) 

seeks to improve the effectiveness, efficiency, and accountability of federal 

programs by establishing a system for agencies to set goals for their 

programs’ performance and to measure results. Thus, the act provides a 

framework to translate the Forest Service’s mission priorities into on-theground projects and activities. 

The Forest Service has made some progress in identifying issues relating to 

ecological, economic, and social sustainability and in developing statutorily 

required strategic goals and objectives as well as strategies to achieve 

them. In particular, the agency is refining the goals and objectives in its 

strategic plan and linking them to long-term performance measures and 5-

year milestones that better focus on outcomes and results to be achieved 

over time.9

 In addition, the agency is developing strategies to achieve some 

of the ecological goals and objectives in the strategic plan, such as reducing 

the incidence of uncontrollable and often catastrophic wildfires10 and 

restoring degraded watersheds.

9

Draft USDA Forest Service Strategic Plan (2000 Revision), U.S. Department of Agriculture, 

Forest Service (Nov. 1999).

10Protecting People and Sustaining Resources in Fire-Adapted Ecosystems: A Cohesive 

Strategy, Forest Service (Apr. 13, 2000).
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In testimony before the Subcommittee on Interior and Related Agencies, 

House Committee on Appropriations, on February 16, 2000, the Chief of the 

Forest Service said that the agency expects that “forest plan goals, 

objectives, and performance measures will be aligned with the agency’s 

goals, objectives, and performance measures.”11 However, the proposed 

planning regulations do not require that forest plans be clearly linked to the 

agency’s strategic goals, objectives, and strategies. Instead, the regulations 

state that officials should consider national-level, long-term strategic goals 

and objectives, among other things, in managing the national forests. The 

most substantive direction provided on how and where to incorporate 

national priorities into forest plans is found in the definition of “resource 

management goal.” The proposed regulations would require forest plans to 

include “general, non-quantitative” resource management goals, which the 

regulations define as “statements of intent” that link “laws, executive 

orders, regulations, and applicable Forest Service strategic plans with 

specific measurable objectives.” No further direction is given on how this 

should be done. 

According to one Forest Service official involved in finalizing the agency’s 

proposed planning regulations, the proposed regulations are fully 

responsive to the Chief’s expectation that forest plans will be aligned with 

the strategic plan. Conversely, officials within the Forest Service’s 

headquarters office responsible for the agency’s strategic plan said they 

believe that to comply with the requirements of the Results Act and the 

Chief’s expectation, the proposed regulations must be revised to require 

that the goals and objectives of field units be linked to the agency’s 

strategic goals and objectives and that strategic goals and objectives drive 

those of all other plans. 

11Managerial Accountability In the Forest Service: A Review of the NAPA and GAO Reports 

on Accountability, Testimony of Mike Dombeck, Chief, Forest Service, U.S. Department of 

Agriculture.
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The approach taken by the Department of the Interior’s National Park 

Service suggests some positive insights for the Forest Service in linking 

plans to results. The Park Service already requires the 376 separate units in 

the National Park System to prepare local land management plans (similar 

in function to forest plans) that address applicable servicewide goals as 

well as goals specific to each unit’s unique legislative and operating 

environments.12

The Proposed 

Regulations Would Not 

Hold the National 

Forests Accountable 

for Ensuring Effective 

Public Participation, 

Monitoring, and Data 

Collection 

The Forest Service has long acknowledged the importance of involving the 

public and other government agencies throughout the planning process and 

basing decisions on sound information. However, the agency has often left 

implementation of these key elements of forest planning to the discretion 

of its independent and autonomous forests. As a result, these forests have 

sometimes (1) based their decisions on inaccurate or incomplete data; (2) 

not adequately involved the public and other government agencies 

throughout their forest planning process; and (3) failed to live up to 

monitoring requirements, particularly those for monitoring the effects of 

past planning decisions. These deficiencies have driven up the cost and 

time to develop forest plans and driven down the agency’s ability to achieve 

planned objectives. 

Building on the lessons learned, the Forest Service’s 1995 proposed 

planning regulations would have held the national forests more 

accountable for their performance in developing and implementing forest 

plans by requiring them to (1) develop strategies for involving the public 

and other government agencies in their planning processes and for 

monitoring and evaluating their management decisions and (2) make the 

strategies available to the public. Similarly, we have recommended that the 

agency revise its proposed planning regulations to require the national 

forests to develop strategies to gather data on ecological, social, and 

economic issues that extend beyond their administrative borders and to 

integrate these data into their forest planning processes. However, the 

Forest Service’s 1999 proposed planning regulations do not require the 

forests to develop these strategies. According to the preamble to the 1999 

proposed regulations, the effort that resulted in the 1999 proposed 

regulations was intended to have a perspective independent of the earlier 

effort. Moreover, although the Forest Service agrees that broad-scale, 

12National Park Service: Efforts to Link Resources to Results Suggest Insights for Other 

Agencies (GAO/AIMD-98-113, Apr. 10, 1998).
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ecosystem-based assessments should be used in revising forest plans, it 

does not think that a requirement to develop such a strategy should occur 

in the rule itself. Instead, the Forest Service responded that it will include 

requirements for gathering and integrating data into the forest planning 

process into a system of manuals and handbooks that provide details to the 

forests on how to implement the “spirit and intent” of the planning 

regulations.

The 1995 Proposed Planning 

Regulations Would Have 

Held the Forests More 

Accountable for Ensuring 

Effective Public 

Participation

The agency’s existing planning regulations require the Forest Service to use 

public participation activities early and often, as applicable, throughout the 

planning process. Similarly, the 1999 proposed planning regulations 

describe the importance of public participation in the agency’s decisionmaking and state that, in order to integrate the public into the planning 

process, the public should be provided with frequent and early 

opportunities to participate. Both the existing and the proposed planning 

regulations give significant discretion to individual forest supervisors to 

determine how and to what extent to involve the public in developing 

forest plans. The 1995 proposed planning regulations would have also given 

forest supervisors considerable discretion in determining how and to what 

extent to involve the public in developing forest plans. However, the 1995 

proposed regulations would have also required forest supervisors to (1) 

develop “communications strategies” describing how the public and other 

governmental entities would participate in all stages of revising a forest 

plan and (2) invite the public and others to express their ideas and 

suggestions on the strategies. In addition, the 1995 proposed regulations 

would have required forest supervisors to (1) meet with interested 

representatives of other federal agencies and state, local, and tribal 

governments to establish and document procedures for ongoing 

coordination and communication throughout the plan revision process and 

(2) document these procedures and make them available to the public. 

Documenting public participation and interagency coordination strategies 

establishes a basis for holding the supervisors more accountable for their 

performance. 
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The 1995 Proposed Planning 

Regulations Would Have 

Held the Forests More 

Accountable for Monitoring 

and Evaluating Management 

Decisions

Under the agency’s existing planning regulations, forest plans must contain 

provisions requiring periodic monitoring of the plan’s implementation to 

assess how well the plan’s objectives have been met and how closely 

management standards and guidelines have been applied. Similarly, the 

1999 proposed planning regulations acknowledge the importance of, and 

generally describe the purpose for, monitoring and evaluation. However, 

neither the existing nor the 1999 proposed planning regulations provide 

sufficient guidance to ensure that monitoring and evaluation activities are 

effective. In particular, the proposed regulations do not require forest 

supervisors to (1) prioritize their monitoring and evaluation needs, (2) 

describe procedures for implementing monitoring and evaluation activities, 

or (3) identify needed changes to plans or plans’ implementation. 

Conversely, the 1995 proposed planning regulations would have required 

forest supervisors to prepare a comprehensive monitoring and evaluation 

strategy that would have, among other things, (1) provided instructions for 

prioritizing monitoring and evaluation activities and for determining if their 

results warrant changes to management decisions and (2) described the 

procedures for implementing monitoring and evaluation activities. The 

1995 proposed regulations would have also required forest supervisors to 

make the strategies available to the public for review and comment at the 

same time as the proposed forest plans. In addition, the 1995 proposed 

regulations would have required forest supervisors to identify any needed 

changes to plans or plans’ implementation in annual monitoring and 

evaluation reports.

Neither the 1995 nor the 

1999 Proposed Planning 

Regulations Would Hold the 

Forests Adequately 

Accountable for Data 

Collection and Use

The agency’s existing planning regulations require forest supervisors to 

obtain current inventory data on forest resources. However, since the 

agency adopted these regulations, its need for gathering better and more 

comprehensive information on which to base decisions has increased. In 

particular, in revising their plans, most, if not all, of the national forests will 

need to address ecological, social, and economic issues that extend beyond 

their administrative boundaries and often extend onto other national 

forests. 

In the early 1990s, the Forest Service began using ecosystem-based 

assessments to address broad-scale ecological and socioeconomic issues. 

Both the 1995 and the 1999 proposed planning regulations address some of 

the lessons the agency has learned about conducting and using such 

assessments. For instance, the 1999 proposed regulations state that (1) 

forest plans must be based on the best available scientific information and 

analyses, including information from a variety of geographic areas, some of 
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which can only be obtained, or can best be obtained, from broad-scale 

assessments and (2) broad-scale assessments should be conducted at 

appropriate geographic scales and reach conclusions.

However, neither the 1995 nor the 1999 proposed regulations adequately 

reflect other lessons learned about conducting broad-scale, ecosystembased assessments. For example, the 1999 proposed regulations (1) 

generally leave decisions about whether to conduct assessments to the 

discretion of the Forest Service’s national forest supervisors, who have 

considerable autonomy for interpreting and applying the agency’s policies; 

(2) do not state when in the process assessments should occur; (3) are 

silent on the need for clear objectives and identifiable products; and (4) do 

not require the regional offices and forests to identify their strategies for 

involving the public.

Our February 2000 report on the Forest Service’s planning process included 

recommendations to better integrate broad-scale assessments into forest 

planning. Specifically, we recommended that the 1999 proposed planning 

regulations be revised to make clear that the regions and forests must use 

broad-scale, ecosystem-based assessments in revising forest plans unless 

they can justify their omission. We also recommended that the regulations 

be revised to make clear that when a decision is made to conduct an 

assessment, the region(s) and forests must prepare a strategy that 

identifies, among other things, (1) how the assessment will be linked to the 

forest plan’s revision; (2) how the public and other governmental entities 

will participate in the revision process; (3) what objectives the assessment 

will meet and what products it will generate, including those of the highest 

priority; and (4) how much the assessment will cost, how funding will be 

secured for it, and what is likely to happen if full funding is not available.

In responding to our recommendations, the Forest Service agreed with 

their intent and desired outcome. However, rather than revise the 1999 

proposed planning regulations, the agency plans to place the necessary 

direction and guidance in its system of directives that provide details to the 

forest on how to implement the “spirit and intent” of the planning revisions. 

Conclusions By making clear that ecological sustainability—rather than economic or 

social sustainability—is the Forest Service’s highest mission priority, the 

agency’s proposed planning regulations, when finalized, would provide the 

national forests with needed direction on how to resolve conflicts among 

competing uses when developing and implementing forest plans. However, 
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establishing ecological sustainability as the agency’s highest mission 

priority is better done outside procedural regulations governing forest 

planning. 

Other improvements to the Forest Service’s planning process are best 

addressed in the agency’s planning regulations. These include the need to 

(1) clearly link forest plans to the goals and objectives in the Forest 

Service’s statutorily required strategic plan as well as to the strategies to 

achieve them and (2) develop strategies to involve the public and other 

government agencies throughout the planning process and to base 

decisions on sound information. However, the agency’s 1999 proposed 

planning regulations do not (1) clearly link forest plans to the strategic 

goals, objectives, and strategies and (2) address some of the lessons 

learned on public participation and monitoring that were identified during 

the development of, and incorporated in, the 1995 proposed planning 

regulations. Since the Forest Service plans to finalize the 1999 proposed 

planning regulations early in October, 2000, it would be difficult for the 

agency to revise the regulations to require the national forests to (1) 

develop strategies for involving the public and other government agencies 

in their planning processes and for monitoring and evaluating their 

management decisions and (2) make the strategies available to the public. 

Therefore, the Forest Service may need to place the necessary direction 

and guidance relating to these key elements of forest planning in its system 

of directives that provide details to the forests on how to implement the 

planning regulations. However, because the national forests are primarily 

responsible for implementing many of the strategic goals, objectives, and 

strategies, the proposed planning regulations should be revised—even at 

this late hour—to require that forest plans be clearly linked to the Forest 

Service’s strategic plan. 

Recommendations to 

the Secretary of 

Agriculture 

Although the Forest Service’s 1999 proposed planning regulations would 

help national forests to resolve conflicts among competing uses when 

developing and implementing forest plans by making clear that ecological 

sustainability is the agency’s highest priority, the Congress has never 

explicitly accepted this as the Forest Service’s highest priority. Therefore, 

we recommend that the Secretary of Agriculture direct the Chief of the 

Forest Service to work with the Congress to ensure agreement on what the 

agency’s mission priorities should be. 

Moreover, since forest plans play a pivotal role in translating the agency’s 

strategic goals, objectives, and strategies into on-the-ground projects and 
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activities, we also recommend that the Secretary of Agriculture direct the 

Chief of the Forest Service to revise the agency’s proposed planning 

regulations to (1) require national forests to clearly link their forest plans to 

the agency’s strategic goals, objectives, and strategies and (2) blend them 

with local priorities in revising the forest plans.

Finally, while we continue to believe that it would be preferable to place 

the necessary direction and guidance relating to public participation and 

monitoring in the Forest Service’s planning regulations, we recommend 

that the Secretary of Agriculture direct the Chief of the Forest Service to, at 

a minimum, revise the agency’s system of directives to require the national 

forests to develop (1) communications strategies describing how the public 

and other governmental entities will participate in all stages of revising a 

forest plan and (2) comprehensive monitoring and evaluation strategies 

describing how implementation of the plan will be monitored to determine 

how well their objectives and requirements have been met and how the 

data will be used to make changes to management decisions. We also 

recommend that the forests be required to (1) involve the public and other 

interested parties in developing these strategies and (2) make the strategies 

available to the public as a basis for holding the forests more accountable 

for their performance. 

Agency Comments and 

Our Evaluation

We provided a draft of this report to the Forest Service for its review and 

comment. Although the Forest Service generally agreed with the desired 

outcomes of our recommendations, it did not agree that our 

recommendations are needed to accomplish the outcomes. For example, 

we both believe that there should be a “direct link” between forest plans 

and the agency’s national-level, long-term strategic goals and objectives. 

However, the Forest Service believes that requiring forest supervisors to 

“consider” the strategic goals and objectives in managing the national 

forests is adequate to ensure this link is established. Similarly, we share 

Forest Service’s view that the forest supervisors should (1) base their 

decisions on accurate and complete data; (2) adequately involve the public 

and other government agencies throughout the forest planning process; 

and (3) live up to monitoring requirements. However, we also believe that 

forest supervisors should be required to develop strategies to ensure these 

key elements are integrated into the forest planning process. Finally, the 

Forest Service believes that ecological sustainability must be its highest 

priority. However, neither ecological sustainability nor the priority that the 

agency assigns to it is specifically required by any law, and until the 

Congress and the agency reach agreement on ecological sustainability as 
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the Forest Service’s highest priority, holding the agency accountable for its 

performance will be difficult. The Forest Service’s comments and our 

responses appear in appendix I.

We conducted our work between March 2000 and August 2000 in 

accordance with generally accepted government auditing standards. 

Appendix II contains the details of our scope and methodology.

We are sending copies of this report to Chairman Frank Murkowski, Senate 

Committee on Energy and Natural Resources; Senator Jeff Bingaman, 

Ranking Minority Member, Senate Committee on Energy and Natural 

Resources; Senator Ron Wyden, Ranking Minority Member, Subcommittee 

on Forests and Public Land Management, Senate Committee on Energy and 

Natural Resources; Chairman Don Young, House Committee on Resources; 

Representative George Miller, Ranking Minority Member, House 

Committee on Resources; Representative Adam Smith, Ranking Minority 

Member, Subcommittee on Forests and Forest Health, House Committee 

on Resources; the Honorable Dan Glickman, Secretary of Agriculture; and 

the Honorable Mike Dombeck, Chief of the Forest Service. We will also 

make copies available to others on request.

If you have any questions about this report, please contact me at (202) 512-

3841. Key contributors to this assignment were Charles S. Cotton, Charles 

T. Egan, Kathy Hale, and Richard P. Johnson.

Barry T. Hill 

Associate Director, Energy, Resources,

 and Science Issues
Page 16 GAORCED-00-256 Forest Service

Appendix I

Comments From the Forest Service and Apendxies

GAO’s Response ApendxiI

Note: GAO comments 

supplementing those in 

the report text appear at 

the end of this appendix.

See comment 1.

See comment 2.
Appendix I

Comments From the Forest Service and 

GAO’s Response

Page 17 GAORCED-00-256 Forest Service

See comment 3.

See comment 4.
Appendix I

Comments From the Forest Service and 

GAO’s Response

Page 18 GAORCED-00-256 Forest Service

See comment 5.
Appendix I

Comments From the Forest Service and 

GAO’s Response

Page 19 GAORCED-00-256 Forest Service
Appendix I

Comments From the Forest Service and 

GAO’s Response

Page 20 GAORCED-00-256 Forest Service

The following are GAO’s comments on the Forest Service’s letter dated 

September 25, 2000. 

GAO Comments 1. According to the Forest Service, “ecological sustainability is not only a 

complement to multiple-use and sustained yield management, but it is 

absolutely necessary for its achievement.” However, the priority assigned 

to ecological sustainability by the agency is not driven by the statutory 

authorities specific to the management of the national forests, but rather, is 

predicated on the general requirements in environmental laws. Further, the 

Congress has never explicitly accepted ecosystem sustainability as the 

Forest Service’s highest priority or acknowledged its effects on the 

availability of timber, recreation, and other goods and services on the 

national forests. Because the priority the Forest Service places on 

sustaining ecosystems is both controversial and fundamental to the 

management of national forests, we believe that explicit agreement with 

the Congress on this subject is warranted and recommend that the 

Secretary of Agriculture work to obtain such agreement.

2. According to the Forest Service, section 219.3(b) of the proposed 

regulations provides that there be a “direct link” between forest plans and 

national strategic goals and objectives in the new planning process. 

However, the section merely requires that long-term strategic goals, 

objectives, and outcome measures be “considered” in managing the 

national forests, not that they be clearly linked to the agency’s strategic 

plan.

3. We agree with the Forest Service that the agency’s planning regulations 

should (1) require that forest supervisors provide the public and others 

opportunities to be involved early and often throughout the planning 

process and (2) grant forest supervisors discretion to tailor public 

participation to their specific planning efforts. Both the existing and 1999 

proposed regulations do this. However, under the exiting regulations, some 

forests did not always adequately involve the public and others in the 

planning process and the 1999 proposed regulations are not significantly 

different. We believe the solution is to hold the forest supervisors 

accountable for their actions. Our recommendation— based on the Forest 

Service’s 1995 proposed regulations— would establish a basis for holding 

the supervisors more accountable for their performance by requiring 

national forests to develop, document, and make available a 

communications strategy for involving the public and others in the forest 

planning process. GAO disagrees with the Forest Service that a 
Appendix I

Comments From the Forest Service and 

GAO’s Response

Page 21 GAORCED-00-256 Forest Service

communications strategy could preclude tailoring public involvement 

approaches to the specific planing effort. Forest Supervisors would 

continue to have considerable discretion in determining how and to what 

extent to involve the public in developing forest plans. Additionally, we 

recommend that the public and other interested parties be involved in 

developing these strategies, which could result in public involvement 

approaches more finely tailored to specific planning efforts.

4. We agree with the Forest Service about the importance of (1) monitoring 

and evaluating management decisions and (2) prioritizing monitoring 

activities. However, to ensure that monitoring and evaluation activities are 

effective, we believe the agency’s planning regulations must do more to 

hold supervisors accountable for their actions than require an annual 

monitoring and evaluation report. The annual monitoring and evaluation 

report that would be required by the 1999 proposed regulations is a step in 

the right direction, however, it does not focus on future monitoring and 

evaluation activities. For this reason, we recommend that national forests 

develop monitoring and evaluation strategies, similar to the 

communications strategies we have also recommended, that would 

describe, among other things, procedures for implementing monitoring and 

evaluation activities and how the data will be used to make changes to 

management decisions. Like the communications strategies, the public and 

others should be involved in developing monitoring and evaluation 

strategies and these strategies should be made available to the public as a 

basis for holding the forests more accountable for their performance. 

5. We agree with the Forest Service that the amount and level of data 

collection and synthesis should vary with the issues to be addressed in 

revising a forest plan. However, as stated in our report, in revising forest 

plans, most, if not all, of the national forests will need to address 

ecological, social, and economic issues that extend beyond their 

administrative boundaries. For these reasons, we recommended in our 

February 2000 report that broad scale, ecosystem based assessments be 

used in revising forest plans unless their omission can be justified. Further, 

to ensure that broad scale assessments are used effectively, we also 

recommended in our February 2000 report that the forests prepare a 

strategy that identifies, among other things, the products the assessment 

will generate, their priority and cost, and how they will be used in revising 

forest plans. This is a prudent measure to ensure that, when assessments 

are appropriate, they are integrated effectively into forest planning. We 

believe these recommendations are consistent with a flexible process that 

yields the data appropriate to address an issue and do not mandate one 
Appendix I

Comments From the Forest Service and 

GAO’s Response

Page 22 GAORCED-00-256 Forest Service

approach that may provide too much or too little information to address 

the issue at hand.
Page 23 GAO/RCED-00-256 Forest Service

Appendix II

Objectives, Scope, and Methodology ApendxiI

Over the last 6 years, we have issued over 2 dozen products that have 

identified deficiencies in the Forest Service's planning process and 

included recommendations to improve the cost-effectiveness and 

timeliness of this process. Concerned about the outcome of the required 

forest plan revisions, the Chairman of the Subcommittee on Forests and 

Public Land Management, Senate Committee on Energy and Natural 

Resources, and the Chairman of the Subcommittee on Forests and Forest 

Health, House Committee on Resources, asked us to provide our 

observations on the extent to which the Forest Service's proposed planning 

regulations address these deficiencies and recommendations. 

Our analysis of our prior products identified the need to (1) make clear the 

agency's mission priorities before beginning the process to revise a forest 

plan; (2) link forest plans to agencywide goals, objectives, and strategies; 

and (3) hold the forests more accountable for key elements of forest 

planning. We then reviewed the agency's 1999 proposed planning 

regulations to determine how they addressed each of the three themes. In 

addition, we met with Forest Service officials from the office of the Deputy 

Chief, Programs and Legislation, responsible for developing the agency's 

strategic plan and with officials from the office of the Deputy Chief, 

National Forest System, responsible for drafting the proposed regulations. 

We conducted our work between March 2000 and August 2000 in 

accordance with generally accepted government auditing standards.
Page 24 GAORCED-00-256 Forest Service

Chapter 1

Related GAO Products Chapte1r

Fire Management: Lessons Learned From the Cerro Grande (Los Alamos) 

Fire (GAO/T-RCED-00-257, July 27, 2000).

Forest Service: Actions Needed for the Agency to Become More 

Accountable for Its Performance (GAO/T-RCED-00-236, June 29, 2000).

Tongass National Forest: Process Used to Modify the Forest Plan

(GAO/RCED-00-45, Apr. 17, 2000).

Forest Service: Broad-Scale Assessments Could Be Better Integrated Into 

the Forest Planning Process (GAO/T-RCED-00-146, Apr. 11, 2000).

Forest Service: Status of Efforts to Improve Accountability (GAO/TRCED/AIMD-00-93, Feb. 16, 2000).

Forest Service Planning: Better Integration of Broad-Scale Assessments 

Into Forest Plans Is Needed (GAO/RCED-00-56, Feb. 15, 2000).

Forest Service: A Framework for Improving Accountability

(GAO/RCED/AIMD-00-2, Oct. 13, 1999).

Federal Land Management: Comments on Selected Provisions of S. 1320--A 

Bill to Revise Federal Land Management Planning (GAO/T-RCED-99-270, 

July 22, 1999).

Western National Forests: Status of Forest Service's Efforts to Reduce 

Catastrophic Wildfire Threats (GAO/T-RCED-99-241, June 29, 1999).

Forest Service Priorities: Evolving Mission Favors Resource Protection 

Over Production (GAO/RCED-99-166, June 17, 1999).

Ecosystem Planning: Northwest Forest and Interior Columbia River Basin 

Plans Demonstrate Improvements in Land-Use Planning (GAO/RCED-99-

64, May 26, 1999).

Western National Forests: A Cohesive Strategy is Needed to Address 

Catastrophic Wildfire Threats (GAO/RCED-99-65, Apr. 2, 1999).

Forest Service: Barriers to and Opportunities for Generating Revenue

(GAO/T-RCED-99-81, Feb. 10, 1999).
Chapter 1

Related GAO Products

Page 25 GAORCED-00-256 Forest Service

Western National Forests: Nearby Communities Are Increasingly 

Threatened by Catastrophic Wildfires (GAO/T-RCED-99-79, Feb. 9, 1999).

Forest Service Management: Little Has Changed as a Result of the Fiscal 

Year 1995 Budget Reforms (GAO/RCED-99-2, Dec. 2, 1998).

Western National Forests: Catastrophic Wildfires Threaten Resources and 

Communities (GAO/T-RCED-98-273, Sept. 28, 1998).

Oregon Watersheds: Many Activities Contribute to Increased Turbidity 

During Large Storms (GAO/RCED-98-220, July 29, 1998).

Forest Service: Lack of Financial and Performance Accountability Has 

Resulted in Inefficiency and Waste (GAO/T-RCED/AIMD-98-135, Mar. 26, 

1998).

Forest Service: Barriers to Generating Revenue or Reducing Costs

(GAO/RCED-98-58, Feb. 13, 1998).

The Results Act: Observations on the Forest Service's May 1997 Draft Plan

(GAO/T-RCED-97-223, July 31, 1997).

Forest Service Decision-Making: A Framework for Improving Performance

(GAO/RCED-97-71, Apr. 29, 1997).

Tongass National Forest: Lack of Accountability for Time and Costs Has 

Delayed Forest Plan Revision (GAO/T-RCED-97-153, Apr. 29, 1997).

Forest Service Decision-Making: Greater Clarity Needed on Mission 

Priorities (GAO/T-RCED-97-81, Feb. 25, 1997).

Federal Land Management: Streamlining and Reorganization Issues

(GAO/T-RCED-96-209, June 27, 1996).

Forest Service: Issues Related to Managing National Forests for Multiple 

Uses (GAO/T-RCED-96-111, Mar. 26, 1996).

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

Ecosystem Management: Additional Actions Needed to Adequately Test a 

Promising Approach (GAO/RCED-94-111, Aug. 16, 1994).

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