United States General Accounting Office

GAO Testimony

Before the Subcommittee on Forests and Public Lands

Management, Committee on Energy and Natural

Resources, U. S. Senate

For Release on Delivery

Expected at

2:30 p.m. EST

Tuesday

February 25, 1997

FOREST SERVICE

DECISION-MAKING

Greater Clarity Needed on

Mission Priorities

Statement of Barry T. Hill, Associate Director,

Energy, Resources, and Science Issues,

Resources, Community, and Economic,

Development Division

GAO/T-RCED-97-81

Mr. Chairman and Members of the

Subcommittee:

We are pleased to be here today to discuss the preliminary results of our

work for you and other requesters on the decision-making process used by

the Department of Agriculture’s Forest Service in carrying out its mission.

Your draft bill—entitled the Public Land Management Responsibility and

Accountability Restoration Act—is designed to provide the Forest Service

and the Department of the Interior’s Bureau of Land Management with the

authority and ability to effectively manage their lands in accordance with

the principles of multiple use and sustained yield and for other purposes.

It does this by supplementing the agencies’ planning statutes and other

laws that apply to lands managed by the two agencies. As agreed, to help

frame the discussion on your draft bill, we will present our preliminary

views on the underlying causes of inefficiencies and ineffectiveness in the

Forest Service’s decision-making process.

During hearings held during the 104th Congress, we and others testified1

that the Forest Service’s decision-making process is costly and

time-consuming and that the agency often fails to achieve its planned

objectives. The agency has spent over 20 years and over $250 million

developing multiyear plans for managing timber production, livestock

grazing, recreation, wildlife and fish habitat, and other legislatively

mandated uses on national forests. It also spends about $250 million a year

for environmental studies to support individual projects. However,

according to an internal Forest Service report, inefficiencies within this

process cost up to $100 million a year at the project level alone. In

addition, by the time the agency has completed its decision-making, it

often finds that it is unable to achieve the plans’ objectives or implement

planned projects because of changes in natural conditions and funding, as

well as new information and events.

In summary, Mr. Chairman, our ongoing work has identified three

underlying causes of inefficiency and ineffectiveness in the Forest

Service’s decision-making process:

• First, the agency has not given adequate attention to improving its

decision-making process, including improving its accountability for

expenditures and performance. As a result, long-standing deficiencies

within its decision-making process that have contributed to increased

costs and time and/or the inability to achieve planned objectives have not

been corrected.

1

See, for example, Forest Service: Issues Relating to Its Decisionmaking Process (GAO/T-RCED-96-66,

Jan. 25, 1996) and Forest Service: Issues Related to Managing National Forests for Multiple Uses

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

Page 1 GAO/T-RCED-97-81
Mr. Chairman and Members of the

Subcommittee:

• Second, issues that transcend the agency’s administrative boundaries and

jurisdiction have not been adequately addressed. In particular, the Forest

Service and other federal agencies have had difficulty reconciling the

administrative boundaries of national forests, parks, and other federal land

management units with the boundaries of natural systems, such as

watersheds and vegetative and animal communities, both in planning and

in assessing the cumulative impact of federal and nonfederal activities on

the environment.

• Third, the requirements of numerous planning and environmental laws,

enacted primarily during the 1960s and 1970s, have not been harmonized.

As a result, differences among the requirements of different laws and their

differing judicial interpretations require some issues to be analyzed or

reanalyzed at different stages in the different decision-making processes of

the Forest Service and other federal agencies without any clear sequence

leading to their timely resolution. Additional differences among the

statutory requirements for protecting resources—such as endangered and

threatened species, water, air, diverse plant and animal communities, and

wilderness—have also sometimes been difficult to reconcile.

However, on the basis of our work to date, we believe that statutory

changes to improve the efficiency and effectiveness of the Forest Service’s

decision-making process cannot be identified until agreement is first

reached on which uses the agency is to emphasize under its broad

multiple-use and sustained-yield mandate and how it is to resolve conflicts

or make choices among competing uses on its lands. Disagreement over

which uses should receive priority, both inside and outside the agency, has

also inhibited the Forest Service in establishing the goals and performance

measures needed to ensure its accountability.

The Forest Service

Has Not Given

Adequate Attention to

Improving Its

Decision-Making

Process

Reducing the costs and time of its decision-making and improving its

ability to deliver what is expected or promised have not been given

adequate attention throughout the Forest Service. As a result, deficiencies

within the decision-making process that have been known to the agency

for a decade or more have not been corrected. To compensate for the

increased costs and time of decision-making and the inability to

implement planned projects, the Forest Service must request more annual

appropriations to achieve fewer planning objectives.

The Chief Financial Officers Act of 1990 requires the agency to be more

accountable for its expenditures of appropriated funds by requiring it to

develop integrated accounting and financial management systems that are

Page 2 GAO/T-RCED-97-81
Mr. Chairman and Members of the

Subcommittee:

to provide complete, reliable, consistent, and timely financial information.

However, the Forest Service has made little progress in implementing the

act’s provisions. An audit of the agency’s financial statements for fiscal

year 1995 by Agriculture’s Inspector General resulted in an adverse

opinion because of “pervasive errors, material or potentially material

misstatements, and/or departures from applicable Government accounting

principles affecting several Financial Statement accounts.”2

 Among the

audit’s findings, the Inspector General reported that the Forest Service

could not account for expenditures of $215 million in fiscal year 1995. As a

result, Forest Service managers are unable to adequately monitor and

control spending levels for various programs and activities relating to

decision-making or to measure the extent to which changes affect costs

and efficiency. Corrective actions to address accounting and financial

reporting problems identified by the Inspector General are not scheduled

to be implemented until the end of fiscal year 1998.

Similarly, the Forest Service has not been successful in achieving the

objectives in its forest plans or implementing planned projects. For

example, in response to congressional concerns about the Forest Service

not being able to deliver what is expected or promised, the Chief, in the

fall of 1991, formed a task force of employees from throughout the agency

to review the issue of accountability. The task force’s February 1994 report

set forth a seven-step process to strengthen accountability. Steps in the

process include (1) establishing work agreements that include measures

and standards with customer involvement, (2) assessing performance, and

(3) communicating results to customers. However, the task force’s

recommendations were never implemented. Rather, they were identified

as actions that the agency plans to implement over the next decade.

The task force’s recommendations, as well as those in other studies, are

intended to address some of the long-standing deficiencies within the

Forest Service’s decision-making process that have driven up costs and

time and/or driven down the ability to achieve planned objectives. These

deficiencies include (1) not adequately monitoring the effects of past

management decisions, (2) not maintaining a centralized system of

comparable environmental and socioeconomic data, and (3) not

adequately involving the public throughout the decision-making process.

For example, adequate monitoring of the effects of past management

decisions is critical to accurately estimate the effects of similar future

2

Audit of Forest Service’s Fiscal Year 1995 Financial Statements (Audit Report No. 08401-4-At, Office

of Inspector General, Department of Agriculture).

Page 3 GAO/T-RCED-97-81
Mr. Chairman and Members of the

Subcommittee:

decisions, including their cumulative impact. Moreover, monitoring can be

used as an effective tool when the effects of a decision may be difficult to

determine in advance because of uncertainty or costs. However, the Forest

Service (1) has historically given low priority to monitoring during the

annual competition for scarce resources, (2) continues to approve projects

without an adequate monitoring component, and (3) does not require its

managers to report on the results of monitoring, as its current regulations

require.

Because of the inefficiencies in its decision-making process, the Forest

Service must request more funds to accomplish fewer objectives during

the yearly budget and appropriation process. For example, in fiscal year

1991, the Congress asked the Forest Service to develop a multiyear

program to reduce the costs of its timber program by not less than 5

percent per year. The Forest Service responded to these and other

concerns by undertaking three major cost-efficiency studies and is

preparing to undertake a fourth. However, with no incentive to act, the

agency has not implemented any of the recommended improvements

agencywide. In the interim, the costs associated with preparing and

administering timber sales have continued to rise. As a result, for fiscal

year 1998, the agency is requesting $12 million, or 6 percent, more for

timber sales management than was appropriated for fiscal year 1997 while

proposing to offer 0.4 billion board feet, or 10 percent, less timber for sale.

The Government Performance and Results Act of 1993 is designed to hold

federal agencies more accountable for their performance by requiring

them to establish performance goals, measures, and reports that provide a

system of accountability for results. In addition, the Clinger-Cohen Act of

1996 (formerly entitled the Information Technology Management Reform

Act of 1996) and the Paperwork Reduction Act of 1995 are intended to

hold federal agencies more accountable for the adequacy of their

information systems and data by providing that they shall establish goals,

measure performance, and report on how well their information

technology and data are supporting their mission-related programs.

Although it is still too early to tell what impact these laws, together with

the Chief Financial Officers Act, will have on the Forest Service, they

provide a useful framework for strengthening accountability within the

agency and improving the efficiency and effectiveness of its

decision-making.

Page 4 GAO/T-RCED-97-81
Mr. Chairman and Members of the

Subcommittee:

Interagency Issues

Affect the Forest

Service’s

Decision-Making

Issues that transcend the agency’s administrative boundaries and

jurisdiction also affect the efficiency and effectiveness of the Forest

Service’s decision-making process. These issues include reconciling

differences in the geographic areas that must be considered in reaching

decisions under different planning and environmental laws.

The Forest Service and other federal land management agencies are

authorized to plan primarily along administrative boundaries, such as

those defining national forests and parks. Conversely, environmental

statutes and regulations require the agencies to analyze environmental

issues and concerns along the boundaries of natural systems, such as

watersheds and vegetative and animal communities. For example,

regulations implementing the National Environmental Policy Act require

the agencies to assess the cumulative impact of federal and nonfederal

activities on the environment.

Because the boundaries of administrative units and natural systems are

frequently inconsistent, federal land management plans have often

considered effects only on portions of natural systems or portions of the

habitats of wide-ranging species, such as migratory birds, bears, and

anadromous fish (including salmon). For example, the Interior Columbia

River Basin contains 74 separate federal land units, including 35 national

forests and 17 Bureau of Land Management districts, each with its own

plan. Not analyzing effects on natural systems and their components at the

appropriate ecological scale results in duplicative environmental

analyses—in individual plans and projects—increasing the costs and time

required for analysis and reducing the effectiveness of federal land

management decision-making.

Addressing issues that transcend the administrative boundaries and

jurisdictions of the Forest Service and of other federal agencies will, at a

minimum, require unparalleled coordination and cooperation among

federal agencies. However, federal land management and regulatory

agencies sometimes do not work efficiently and effectively together to

address issues that transcend their boundaries and jurisdictions.

Disagreements often stem from differing evaluations of environmental

effects and risks, which in turn reflect the agencies’ disparate missions and

responsibilities.

Effective interagency coordination, in turn, requires comparable

environmental and socioeconomic data. However, the data gathered by

Page 5 GAO/T-RCED-97-81
Mr. Chairman and Members of the

Subcommittee:

federal agencies are often not comparable, large gaps in the information

exist, and federal agencies lack awareness of who has what information.

Over the past few years, several major studies have examined the need to

reconcile the differences in the geographic areas that federal agencies

must consider when reaching decisions.3

 Among the options that have

been suggested are changes to the Council on Environmental Quality’s

regulations and guidance implementing the procedural provisions of the

National Environmental Policy Act. According to Council officials,

changes to the act’s regulations and guidance are not being considered at

this time. Instead, the Council plans to rely primarily on less binding

interagency agreements. However, since federal agencies sometimes do

not work efficiently and effectively together to address issues that

transcend their boundaries and jurisdictions and often lack the

environmental and socioeconomic data required to make informed

decisions, strong leadership by the Council would help to ensure that

interagency agreements accomplish their intended objectives.

Differences in 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. Differences among their requirements and differing

judicial interpretations of their requirements have caused some issues to

be analyzed or reanalyzed at various stages in the Forest Service’s

decision-making process, as well as in the decision-making processes of

other federal agencies, without their timely resolution, increasing the costs

and time of decision-making and reducing the ability of the Forest Service

and other land management agencies to achieve the objectives in their

plans.

New information and events can affect the outcomes of the Forest

Service’s decisions and prevent the agency from achieving the objectives

in its forest plans or implementing planned projects. For instance, the

listing of a species as endangered or threatened under the Endangered

Species Act after a forest plan has been approved requires the Forest

Service to reinitiate formal consultations with the Fish and Wildlife

Service and/or the National Marine Fisheries Service to amend or revise

3

See, for example, The Ecosystem Approach: Healthy Ecosystems and Sustainable Economies, Volume

II - Implementation Issues, Report of the Interagency Ecosystem Management Task Force (Nov. 1995);

Ecosystem Management: Additional Actions Needed to Adequately Test a Promising Approach

(GAO/RCED-94-111, Aug. 16, 1994); and Final Report of Recommendations: Project-Level Analysis

Re-Engineering Team, Forest Service (Nov. 17, 1995).

Page 6 GAO/T-RCED-97-81
Mr. Chairman and Members of the

Subcommittee:

the plan. The listing may also prohibit the agency from implementing

projects under the plans that may affect the species until the new round of

consultations has been completed. For example, recent federal court

decisions required the Forest Service to reinitiate consultations on several

approved forest plans after a species of salmon in the Pacific Northwest

and a species of owl in the Southwest were listed as threatened under the

Endangered Species Act. The courts’ rulings prohibited the agency from

implementing projects under the plans that might affect the species until

the new rounds of consultations with the Fish and Wildlife Service and/or

the National Marine Fisheries Service had been completed.

Additionally, through differing judicial interpretations of the same

statutory requirements, the courts have established conflicting

requirements. For example, three federal circuit courts of appeals have

held that the approval of a forest plan represents a decision that can be

judicially challenged and prohibited from being implemented. Conversely,

two other federal circuit courts of appeals have held that a forest plan

does not represent a decision and that only a project can be judicially

challenged, at which time the adequacy of the plan’s treatment of

larger-scale environmental issues arising in the project can be

reconsidered.

Requirements to consider new information and events, coupled with

differing judicial interpretations of the same statutory requirements, have

made it difficult for the Forest Service and other federal agencies to

predict when any given decision can be considered final and can be

implemented. Agency officials perceive that the same issues are recycled

under different planning and environmental laws rather than resolved in a

timely manner.

In addition, environmental laws generally address individual resources,

such as endangered and threatened species, water, and air. Conversely,

planning statutes generally establish objectives for multiple resources,

such as sustaining diverse plant and animal communities, securing

favorable water flow conditions, and preserving wilderness. These

different approaches to achieving similar environmental objectives have

sometimes been difficult for the Forest Service and other federal agencies

to reconcile, at least in the short term. For example, prescribed burning to

restore the forests’ health and to sustain diverse plant and animal

communities may be appropriate under the National Forest Management

Act but may be difficult to reconcile in the short term with air quality

standards under the Clean Air Act.

Page 7 GAO/T-RCED-97-81
Mr. Chairman and Members of the

Subcommittee:

In March 1995, the Secretary of Agriculture pledged to work with the

Congress to identify statutory changes to improve the processes for

implementing the Forest Service’s mission. However, neither his analysis

nor options for changing the current statutory framework suggested by the

Forest Service in 1995 have been sent to the Congress. Administration

officials have said that they are hesitant to suggest changes to the

procedural requirements of planning and environmental laws because they

believe that the Congress may also make substantive changes to the laws

with which they would disagree.

The Forest Service

Needs Guidance on

How to Resolve

Conflicts Among

Competing Uses

On the basis of our work to date, we believe that statutory changes to

improve the efficiency and effectiveness of the Forest Service’s

decision-making process cannot be identified until after agreement is

reached on which uses the agency is to emphasize under its broad

multiple-use and sustained-yield mandate and how it is to resolve conflicts

or make choices among competing uses on its lands.

Our report to you and other requesters, to be issued this spring, will

identify the increasing shift in emphasis in the Forest Service’s plans from

producing timber to sustaining wildlife and fish. This shift is taking place

in reaction to requirements in planning and environmental

laws—reflecting changing public values and concerns—and their judicial

interpretations, together with social, ecological, and other factors. In

particular, section 7 of the Endangered Species Act represents a

congressional design to give greater priority to the protection of

endangered species than to the current primary missions of the Forest

Service and other federal agencies.4

 When proposing a project, the Forest

Service bears the burden of proof to demonstrate that its actions will not

likely jeopardize listed species.

The increasing emphasis on sustaining wildlife and fish conflicts with the

older emphasis on producing timber and underlies the Forest Service’s

inability to achieve the goals and objectives for timber production set forth

in many of the first forest plans. In addition, this attention to sustaining

wildlife and fish will likely constrain future uses of the national forests,

such as recreation. The demand for recreation is expected to grow and

may increasingly conflict with both sustaining wildlife and fish and

producing timber on Forest Service lands.

4

TVA v. Hill, 437 U.S. 153, 185 (1978).

Page 8 GAO/T-RCED-97-81
Mr. Chairman and Members of the

Subcommittee:

While the agency continues to increase its emphasis on sustaining wildlife

and fish, the Congress has never explicitly accepted this shift in emphasis

or acknowledged its effects on the availability of other uses on national

forests. Disagreement over the Forest Service’s priorities, both inside and

outside the agency, has not only hampered efforts to improve the

efficiency and effectiveness of its decision-making but also inhibited it in

establishing the goals and performance measures needed to ensure its

accountability.

If agreement is to be reached on efforts to improve the Forest Service’s

decision-making and if the agency is to be held accountable for its

expenditures and performance, the Forest Service will need to consult

with the Congress on its strategic long-term goals and desired outcome

measures, as the Government Performance and Results Act requires. Such

a consultation would create an opportunity for the Forest Service to gain a

better understanding of which uses it is to emphasize under its broad

multiple-use and sustained-yield mandate and how it is to resolve conflicts

or make choices among competing uses on its lands.

In summary, Mr. Chairman, the Forest Service’s decision-making process

is broken and in need of repair. While much can be done within the

current statutory framework to improve the efficiency and effectiveness of

the process, strong leadership, both throughout the Forest Service and

within the Council on Environmental Quality, will be required. Moreover,

sustained oversight by the Congress will also be important.

Differences among the requirements of planning and environmental laws

also need to be addressed. However, at a June 1996 hearing at which both

you and we testified,5

 you stressed that “form must follow function” and

that the immediate priority is to clarify the Forest Service’s functions. We

agreed with you then, and we agree with you now. Clarifying priorities

within the Forest Service’s multiple-use and sustained-yield mission

should provide the agency with a better understanding of which uses it is

to emphasize under its broad multiple-use and sustained-yield mandate

and how it is to resolve conflicts or make choices among competing uses

on its lands. Once this is done, the legislative changes that are needed to

clarify or modify congressional intentions and expectations can be

identified.

(141031)

5

See Transcript of Proceedings, U. S. Senate, Committee on Governmental Affairs, Improving

Management and Organization in Federal Natural Resources and Environmental Functions (June 27,

1996) and Federal Land Management: Streamlining and Reorganization Issues (GAO/T-RCED-96-209,

June 27, 1996).

Page 9 GAO/T-RCED-97-81
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