a

GAO

United States General Accounting Office

Report to Congressional Requesters

June 2004 FEDERAL LAND 

MANAGEMENT

Additional Guidance 

on Community 

Involvement Could 

Enhance Effectiveness 

of Stewardship 

Contracting

GAO-04-652
www.gao.gov/cgi-bin/getrpt?GAO-04-652.

To view the full product, including the scope 

and methodology, click on the link above. 

For more information, contact Barry Hill at 

(202) 512-3841 or hillbt@gao.gov. 

Highlights of GAO-04-652, a report to

congressional requesters 

June 2004

FEDERAL LAND MANAGEMENT

Additional Guidance on Community 

Involvement Could Enhance 

Effectiveness of Stewardship Contracting 

Although the Forest Service provided limited initial guidance on establishing 

contracting and financial controls, the eight stewardship projects GAO 

visited had incorporated such controls. (BLM was first granted stewardship 

authority in 2003 and had no projects under way at the time of GAO’s 

review.) The projects generally used pre- and post-award controls, such as 

reviews of contractor bids using preestablished criteria, and performance 

and payment bonds to ensure completion of required activities. GAO’s 

review of selected financial controls at the projects we visited showed that 

they appeared to have procedures in place to account for retained receipts, 

including tracking funds received and expended, and had incorporated 

procedures designed to ensure the completion of specific work tasks before 

contractors were paid. Both the Forest Service and BLM issued guidance in 

January 2004 containing such controls for future projects. 

The Forest Service initially provided minimal guidance on soliciting and 

incorporating public involvement in stewardship contracting projects and, as 

a result, the type and extent of efforts to involve communities varied 

considerably among the projects GAO reviewed. However, managers who 

did not incorporate public input may have missed valuable opportunities to 

strengthen their projects. For example, one project manager said that public 

involvement led to more stringent criteria for protecting water quality, and 

another reported that public involvement improved agency access to public 

lands needing fuel reduction. Although most managers GAO spoke with said 

they wanted additional guidance on public involvement, the Forest Service’s 

recently issued stewardship contracting handbook does not contain specific 

guidance for obtaining community input—and BLM’s recent guidance is 

similarly lacking. Without such guidance, each project manager must 

independently determine the type and extent of community involvement to 

solicit and then develop and implement community involvement 

procedures—an inefficient process that could lead to variation in community 

involvement across stewardship contracting projects in both agencies. 

Forest Thinning and Prescribed Burning Undertaken Using Stewardship Contracting 

Authority 

In their efforts to reduce hazardous 

fuels and the risk of wildfire on the 

nation’s public lands, the Forest 

Service and the Bureau of Land 

Management (BLM) expect that 

stewardship contracting will play a 

major role. Stewardship 

contracting involves the use of 

contracting authorities—such as 

the exchange of goods for 

services—first authorized in 1998 

and intended to help the agencies 

achieve land management goals 

that meet community needs. GAO 

was asked, among other things, to 

determine (1) the contracting and 

financial controls the agencies 

use to ensure accountability in 

managing stewardship contracting 

projects and (2) the steps the 

agencies have taken to involve 

communities in the projects. 

To enhance the effectiveness of 

stewardship contracting and 

improve public trust in the 

agencies, GAO recommends that 

the Secretaries of Agriculture and 

the Interior direct the agencies to 

issue additional guidance on 

community involvement identifying 

best practices in seeking and 

incorporating community input, 

and establish minimum 

requirements for seeking 

involvement on each project. 

In commenting on a draft of this 

report, the Forest Service generally 

agreed with its contents. The 

Department of the Interior did not 

provide comments. 
Page i GAO-04-652 Stewardship Contracting

Contents

Letter 1

Results in Brief 3

Background 5

Most Pilot Projects Are Ongoing and Include Removal of Timber or 

Other Vegetation to Improve Forest Health 8

Despite Limited Initial Guidance, Forest Service Has Incorporated 

Contracting and Financial Controls in Eight of Its Projects, and 

Both Forest Service and BLM Have Included Such Controls in 

Their Recent Guidance 24

The Agencies Have Not Provided Substantial Guidance on 

Community Involvement, and Efforts to Involve Communities 

Varied among Projects 35

Both Agencies Have Additional Projects Planned and Intend to 

Assess the Effectiveness of Stewardship Contracting 41

Conclusions 43

Recommendation for Executive Action 43

Agency Comments and Our Evaluation 43

Appendixes

Appendix I: Forest Service’s Responses to Environmentalists’ Concerns 

about Projects Identified as Problematic 46

Appendix II: Objectives, Scope, and Methodology 55

Appendix III: Pilot Project Names, Locations, Acres Treated, and End 

Dates 62

Appendix IV: Comments from the Department of Agriculture 65

Appendix V: GAO Contacts and Staff Acknowledgments 66

GAO Contacts 66

Staff Acknowledgments 66

Tables Table 1: Selection Criteria Met by Each Pilot Project at Which We 

Conducted Site Visits 58

Table 2: Pilot Project Names, Locations, Acres Treated, and End 

Dates 62

Figures Figure 1: Number of Stewardship Contracting Pilot Projects in 

Each Forest Service Region 10
Contents

Page ii GAO-04-652 Stewardship Contracting

Figure 2: Number of Stewardship Contracting Pilot Projects 

Expected to Be Completed Each Calendar Year through 

2014 11

Figure 3: Helicopter Logging to Reduce Fuels at the Baker City 

Watershed Rehabilitation Pilot Project, 

Wallowa-Whitman National Forest 12

Figure 4: Limestone to Be Added to a Creek to Reduce Acidity at 

the Burns Creek Pilot Project, George 

Washington-Jefferson National Forest 13

Figure 5: Mechanical Thinning at the Antelope Pilot Project, 

Fremont-Winema National Forests 14

Figure 6: Prescribed Burning at the Antelope Pilot Project, 

Fremont-Winema National Forests 15

Figure 7: Installation of Public Toilet at the Treasure Interface Pilot 

Project, Kootenai National Forest 16

Figure 8: Number of Stewardship Contracting Pilot Projects 

Addressing Each Land Management Goal to a Great or 

Very Great Extent 17

Figure 9: Number of Stewardship Contracting Pilot Projects 

Reporting the Use of Each Stewardship Contracting 

Authority 18

Figure 10: Number of Stewardship Contracting Pilot Projects, by 

Project Size 19

Figure 11: Sawlogs at the Fernow Experimental Forest Pilot Project, 

Monongahela National Forest 22

Figure 12: Firewood at the Seven Mile Pilot Project, 

Arapaho-Roosevelt National Forest 23

Figure 13: Slash Pile at the Winiger Ridge Pilot Project, 

Arapaho-Roosevelt National Forest 24

Figure 14: Locations of Stewardship Contracting Pilot Projects 

Visited during Our Review 25

Figure 15: Multiparty Monitoring Team Reviewing Project Site at the 

Clearwater Pilot Project, Lolo National Forest 38
Contents

Page iii GAO-04-652 Stewardship Contracting

Abbreviations

BLM Bureau of Land Management

ccf hundred cubic feet

CERT Clearwater Elk Recovery Team

CSFS Colorado State Forest Service

FACA Federal Advisory Committee Act

FFIS Foundation Financial Information System

HCPC Hell’s Canyon Preservation Council

NEPA National Environmental Policy Act

TSA Timber Sale Accounting

USDA U.S. Department of Agriculture

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Page 1 GAO-04-652 Stewardship Contracting

United States General Accounting Office

Washington, D.C. 20548

A

June 14, 2004 Letr

Congressional Requesters

Recent severe wildfire seasons have focused attention on the state of our 

nation’s forests. Many of these forests have become dense with small, 

tightly spaced trees and thick brush, which—combined with drought, wind, 

and other adverse weather conditions—have fueled extensive wildland 

fires in recent years. Both the Forest Service in the Department of 

Agriculture (USDA) and the Bureau of Land Management (BLM) in the 

Department of the Interior are placing greater emphasis on thinning forests 

and rangelands to help reduce the buildup of potentially hazardous fuels, 

partly in response to the Healthy Forests Restoration Act of 2003.1

 Among 

other things, the act directs the Secretaries of Agriculture and the Interior 

to give priority to hazardous fuel reduction projects that provide for the 

protection of at-risk communities or watersheds, or that implement 

community wildfire protection plans. The Forest Service and BLM, which 

together manage a total of about 450 million acres of federal land, are 

focusing on a new tool they consider essential to their efforts to reduce 

fuels: stewardship contracting.

Stewardship contracting involves the use of any of several contracting 

authorities that were first authorized for use by the Forest Service on a 

pilot basis in October 1998. The Omnibus Consolidated and Emergency 

Supplemental Appropriations Act for 1999 established stewardship 

contracting authority to achieve national forest land management goals 

that meet local and rural community needs.2

 Prominent among the 

stewardship contracting authorities is the ability to (1) trade goods—

timber, for example—for contract services, such as thinning of small trees 

and brush; and (2) retain for use in future stewardship projects any receipts 

generated through selling forest products such as timber, rather than 

returning the receipts to the Department of the Treasury, which is required 

under traditional timber sales. The law stated that the land management 

goals of stewardship contracts include road and trail maintenance, 

watershed restoration, and prescribed burning and noncommercial tree 

removal to improve forest health. Although stewardship contracting was 

initially established as a demonstration project that involved a limited 

1

Pub. L. No. 108-148, 117 Stat. 1887 (2003).

2

Pub. L. No. 105-277, § 347, 112 Stat. 2681-298 (1998).
Page 2 GAO-04-652 Stewardship Contracting

number of individual projects within the Forest Service and was to end in 

2002, the Consolidated Appropriations Resolution of 2003, among other 

things, extended the use of stewardship contracting authority to 2013, 

eliminated the limit on the number of projects, authorized commercial tree 

removal for forest health purposes as a project purpose, and extended the 

authority to BLM.3

Because of your interest in the status of the Forest Service’s and BLM’s 

implementation of stewardship contracting authority, you asked us to 

determine (1) the status of stewardship contracting projects and the land 

management goals they address; (2) the extent to which the agencies have 

contracting and financial controls in place that ensure accountability in 

managing stewardship contracting projects; (3) the steps the agencies have 

taken to involve communities in designing, implementing, and evaluating 

stewardship contracting projects; and (4) each agency’s plans for future 

stewardship contracting activities. In addition, you asked us to determine 

the Forest Service’s response to concerns raised by environmental groups 

about six specific stewardship contracting projects; the results of this work 

are contained in appendix I. 

In conducting our review, we met with Forest Service and BLM 

headquarters officials and reviewed agency documents and guidance 

related to stewardship contracting; conducted a Web-based survey on the 

status of all ongoing and completed stewardship contracting projects as of 

September 30, 2003; visited 8 stewardship contracting project sites, where 

we reviewed project financial and contracting files for evidence of selected 

management controls and met with Forest Service officials, project 

contractors, and local citizens to obtain information about project 

implementation, including community involvement in the projects; 

conducted telephone interviews of officials at 25 project sites regarding 

community involvement efforts; conducted telephone interviews of 

representatives of six environmental organizations and Forest Service 

officials regarding the 6 project sites of concern; and spoke with 

representatives of several conservation and forestry organizations to 

obtain their perspectives on stewardship contracting. While the results of 

our telephone discussions and site visits cannot be projected nationwide, 

they represent a mix of stewardship contracting projects by virtue of their 

geographic diversity; the stewardship contracting authorities being used; 

and project status, objectives, and activities. Appendix II provides further 

3

Pub. L. No. 108-7, § 323, 117 Stat. 275 (2003).
Page 3 GAO-04-652 Stewardship Contracting

details on the scope and methodology of our review. We conducted our 

work between April 2003 and April 2004 in accordance with generally 

accepted government auditing standards.

Results in Brief As of September 30, 2003, the Forest Service had completed 9 pilot 

projects, and another 68 were ongoing, with scheduled project completion 

dates through 2014. BLM did not have any projects under way at the time of 

our survey. The Forest Service pilot projects generally focused on removing 

timber and other vegetation to reduce fuels or improve forest health; some 

projects pursued other activities on national forest lands to benefit local 

communities, such as improving trails or installing new public toilets 

intended to protect water quality. The projects had treated—that is, 

conducted stewardship activities on—about 13,800 acres and were 

expected to treat about 158,000 additional acres.

The Forest Service provided limited initial guidance on how to establish 

contracting and financial controls to provide accountability in managing 

projects, in part to allow project managers to experiment with different 

implementation approaches. Nevertheless, the 8 projects we visited had 

incorporated such controls. The projects generally included preaward 

activities, such as reviews of contractor bids using preestablished criteria 

to ensure thoroughness and objectivity in evaluating bids and awarding 

contracts, and meetings with potential contractors to clarify project 

objectives and contract terms and schedules. Similarly, awarded contracts 

generally included elements such as performance and payment bonds 

designed to ensure proper completion of required activities, and on-theground inspections of contracted work intended to ensure that the work 

was conducted appropriately. Regarding financial controls, the projects we 

visited appeared to have established procedures to account for retained 

receipts from the sale of forest products, including tracking funds received 

and expended. Moreover, these projects had incorporated procedures 

designed to ensure that contractors were paid only upon completion of 

specific work tasks. Both the Forest Service and BLM issued guidance in 

January 2004 containing such controls for future projects. 

The Forest Service initially provided minimal guidance on soliciting and 

incorporating public involvement in stewardship contracting projects and, 

as a result, the type and extent of efforts to involve communities varied 

considerably among the Forest Service projects we reviewed. While some 

Forest Service project managers actively solicited public input in designing 

projects or formed monitoring teams to evaluate their implementation, 
Page 4 GAO-04-652 Stewardship Contracting

others did relatively little to solicit or incorporate public input. 

Unfortunately, managers who did not incorporate public input may have 

missed valuable opportunities to strengthen their projects. For example, 

one manager told us that public involvement in her project led to more 

stringent criteria for protecting water quality during project activities, and 

another manager told us that public involvement in his project helped 

improve agency access to public lands needing fuel reduction. Although 

many managers we spoke with told us they wanted additional guidance on 

how to involve the public, the Forest Service’s recently issued stewardship 

contracting handbook does not contain specific guidance for obtaining 

community input, and BLM’s recent guidance is similarly lacking. Without 

such guidance, Forest Service and BLM project managers must 

independently determine the type and extent of community involvement to 

solicit and then independently develop and implement community 

involvement procedures. Undertaking these activities individually is 

inefficient and could lead to variation in community involvement across 

stewardship contracting projects in both agencies.

The Forest Service and BLM plan to implement several additional 

stewardship projects in fiscal year 2004 and beyond. While the Forest 

Service did not specify the number of additional projects it expects to 

undertake in 2004, BLM officials told us the agency has recently initiated 2 

projects and plans about 34 more projects in fiscal year 2004, and officials 

from both agencies reported that they expect additional stewardship 

contracting projects in the years ahead. Both agencies are planning to 

collect information on ongoing and future projects to help them analyze the 

effectiveness of stewardship contracting relative to other contracting tools.

To more fully realize the potential of stewardship contracting and ensure 

that community involvement is incorporated into stewardship contracting 

projects, we are recommending that the Secretaries of Agriculture and the 

Interior direct the agencies to provide additional guidance to field staff 

clarifying the types of community involvement expected in stewardship 

contracting projects and identifying best practices for soliciting such 

involvement. We provided a draft of this report to the Secretaries of 

Agriculture and the Interior for review and comment. The Forest Service 

generally agreed with our report. The Forest Service’s comment letter is 

presented in appendix IV. The Department of the Interior did not provide 

comments.
Page 5 GAO-04-652 Stewardship Contracting

Background In managing federal lands, the Forest Service and BLM often contract for 

services such as road maintenance, forest thinning, and other activities. 

They also frequently contract to sell forest resources such as timber or 

firewood. Traditionally, these contracts have been executed separately—

service contracts have generally been funded with appropriated funds from 

the agencies’ budgets, while timber has been sold through contracts with 

private purchasers. The Omnibus Consolidated and Emergency 

Supplemental Appropriations Act of 1999 authorized the Forest Service to 

combine these contracting mechanisms by entering into “stewardship end 

result contracts,” under which the agency could use the value of forest 

products sold to offset the cost of contracted services.4

 Under such goodsfor-services contracts, the Forest Service could, for example, pay for 

thinning operations by using the proceeds from any commercial timber 

removed as part of the project. Additional contracting authorities were also 

included in the legislation; the full list of authorities follows. (Stewardship 

contracting authority was initially granted only to the Forest Service; in 

2003 it was extended to BLM.)

• Goods for services allows the agency to use the value of commercial 

products, such as timber, to offset the cost of services received, such as 

thinning, stream improvement, and other activities.

• Designation by description or prescription allows the agency to 

conduct a timber harvest by providing the contractor with a description 

of the desired end result of the harvest. For example, the Forest Service 

might require that all ponderosa pine less than 10 inches in diameter be 

harvested. Ordinarily, cutting any standing tree before a Forest Service 

employee has marked or otherwise designated it for cutting is 

prohibited.

• Multiyear contracting allows the agency to enter into stewardship 

contracts of up to 10 years in length. (Standard service contracts are 

limited to 5 years, although timber sale contracts of up to 10 years were 

already authorized.)

• Retention of receipts allows the agency to retain receipts generated 

from the sale of commercial products removed through stewardship 

4

The Forest Service is authorized to use either contracts or agreements in implementing 

stewardship projects. In this report we refer to all such arrangements as contracts.
Page 6 GAO-04-652 Stewardship Contracting

contracts, rather than returning the funds to the Treasury. Receipts are 

to be applied only to stewardship contracting projects.

• Less than full and open competition exempts the agency from the 

requirement under the National Forest Management Act that all sales of 

timber having an appraised value of $10,000 or more be advertised.5

 

This allows the Forest Service to favor local contractors when soliciting 

contract bids.

• Supervision of marking and harvesting of timber sales exempts the 

agency from the requirement that USDA employees supervise the 

harvesting of trees on Forest Service lands. This has allowed the Forest 

Service to use one state agency to assist in stewardship contracting.6

• Best-value contracting requires the agency to consider other factors—

such as past performance or work quality—in addition to price when 

making stewardship contract award decisions.7

The law authorized 28 stewardship contracts by the Forest Service, of 

which 9 were to be in the Forest Service’s Northern Region.8

 The authority 

of the Forest Service to enter into these contracts was to end on September 

30, 2002. Contracts were to “achieve land management goals for the 

national forests that meet local and rural community needs.” The goals 

listed in the legislation included, but were not limited to,

5

Under the National Forest Management Act of 1976, the Forest Service develops land and 

resource management plans that guide all natural resource management activities on the 

national forests. The act includes provisions governing timber sales from national forest 

lands.

6

The Department of the Interior and Related Agencies Appropriations Act of 2001 

authorized the Forest Service to permit the Colorado State Forest Service (CSFS) to 

conduct watershed restoration and protection services on national forest land in Colorado 

when the CSFS is performing similar services on adjacent state or private land.

7

In contrast to the other stewardship authorities, best-value contracting was not newly 

introduced in the stewardship legislation. The Forest Service and BLM had been permitted 

to procure services on a best-value basis prior to the legislation. Under the stewardship 

contracting legislation, however, the agencies are required—rather than simply permitted—

to use best-value contracting when awarding stewardship contracts.

8

The Forest Service is divided into nine geographic regions. See figure 1.
Page 7 GAO-04-652 Stewardship Contracting

• maintaining or obliterating roads and trails to restore or maintain water 

quality;

• maintaining soil productivity, habitat for wildlife and fisheries, or other 

resource values;

• setting prescribed fires to improve the composition, structure, 

condition, and health of stands or to improve wildlife habitat;

• noncommercially cutting or removing trees or other activities to 

promote healthy forest stands, reduce fire hazards, or achieve other 

noncommercial objectives;

• restoring and maintaining watersheds;

• restoring and maintaining wildlife and fish habitat; and

• controlling noxious and exotic weeds and reestablishing native plant 

species.

The law also required that the Forest Service establish a multiparty 

monitoring and evaluation process to assess each stewardship contract. 

Several subsequent laws modified the requirements of the initial 

stewardship contracting authority. The Consolidated Appropriations Act of 

2000 changed the requirement from 28 stewardship contracts to 28 

stewardship projects, allowing for the possibility that individual projects 

may involve more than one contract.9

 The following year, the Department 

of the Interior and Related Agencies Appropriations Act of 2001 doubled 

the number of authorized projects for a total of 56, requiring that at least 9 

of the newly authorized projects be in the Forest Service’s Northern Region 

and at least 3 in the agency’s Pacific Northwest Region.10 Similarly, a year 

later, the Department of the Interior and Related Agencies Appropriations 

Act of 2002 authorized an additional 28 projects (for a total of 84), again 

requiring that at least 9 of the newly authorized projects be in the Northern 

Region and at least 3 in the Pacific Northwest Region.11 This law also 

9

Pub. L. No. 106-113, 113 Stat. 1501A-201 (1999).

10Pub. L. No. 106-291, 114 Stat. 998 (2000).

11Pub. L. No. 107-63, 115 Stat. 471 (2001).
Page 8 GAO-04-652 Stewardship Contracting

changed the end date of the demonstration project from 2002 to 2004. Most 

recently, the Consolidated Appropriations Resolution of 2003 extended the 

authority to enter into stewardship contracts to 2013, extended 

stewardship contracting authority to BLM, removed the restriction on the 

number of projects that could be implemented under this authority, 

removed the emphasis on noncommercial activities among the land 

management goals listed, and replaced the requirement for multiparty 

monitoring and evaluation of each project with a requirement to monitor 

and evaluate the overall use of stewardship contracting. 

Stewardship contracting projects are subject to environmental and 

resource management laws—such as the National Environmental Policy 

Act (NEPA), the Endangered Species Act, and others—that also apply to 

nonstewardship projects. Responsibility for administering stewardship 

contracting authority at the Forest Service lies within two agency offices: 

the Forest and Rangeland Management Group and the Acquisition 

Management Group. Each of the nine Forest Service regions has 

established a stewardship contracting coordinator to facilitate stewardship 

contracting activities within each region. Within BLM, authority for 

administering stewardship contracting authority resides with its Forest and 

Woodland Management Group. Each of BLM’s 12 state offices also has a 

stewardship contracting coordinator.

Most Pilot Projects Are 

Ongoing and Include 

Removal of Timber or 

Other Vegetation to 

Improve Forest Health

As of September 30, 2003, the Forest Service had completed 9 pilot 

projects, and another 68 were ongoing, with project completion dates 

scheduled through 2014.12 Most projects included the removal of timber 

and other vegetation to reduce fuels or promote forest health, while other 

activities included trail construction, wildlife pond restoration, and public 

toilet installation. The projects had treated about 13,800 acres and were 

expected to treat about 158,000 additional acres. Expected project costs 

and forest product values varied widely: Projects were expected to cost 

from $1,000 to $5.7 million, and the estimated value of forest products to be 

removed as part of the projects varied from $124 to $6.3 million. 

12Although 84 pilot projects were authorized, only 77 were ongoing or completed at the time 

of our review. Additional pilot projects had been initiated, but were terminated prior to our 

review.
Page 9 GAO-04-652 Stewardship Contracting

Sixty-eight of 77 Forest 

Service Pilot Projects Are 

Still Ongoing; Projects 

Commonly Have Focused 

on Removing Vegetation

Forest Service staff reported that as of September 30, 2003, 9 pilot projects 

had been completed—i.e., all contracts associated with these projects were 

completed and closed—and an additional 68 projects were ongoing.13 Pilot 

projects were distributed throughout the Forest Service regions, except for 

the Alaska Region, which had none. As expected, given the requirements of 

the initial legislation, the Northern Region had the most pilot projects. 

Figure 1 shows the distribution of pilot projects by Forest Service region. 

(Appendix III provides a list of all 77 projects and related project details, 

including project acres and expected completion date.)

13The 68 ongoing pilot projects include one, the Granite Watershed Protection and 

Enhancement project, that was authorized by the Granite Watershed Enhancement and 

Protection Act of 1998 (Pub. L. No. 105-281, 112 Stat. 2695) rather than the stewardship 

contracting legislation. A project official told us, however, that the project is being 

conducted under both authorities—the stewardship contracting legislation and the Granite 

Watershed Enhancement and Protection Act of 1998. 
Page 10 GAO-04-652 Stewardship Contracting

Figure 1: Number of Stewardship Contracting Pilot Projects in Each Forest Service Region 

Note: The Forest Service does not have a Region 7.

The earliest reported completion date for a pilot project was May 2001, 

while the latest reported completion date is expected to be 2014. Figure 2 

shows the number of pilot projects expected to be completed each year 

from 2004 until 2014.

Region 5

Pacific Southwest

4 projects

Region 10

Alaska

No projects

Region 6

Pacific Northwest

12 projects

Sources: Forest Service and GAO.

Puerto Rico

Region 1

Northern

24 projects

Region 3

Southwestern

5 projects

Region 8

Southern

12 projects

Region 9

Eastern

6 projects

Region 4

Intermountain

7 projects

Region 2

Rocky Mountain

7 projects
Page 11 GAO-04-652 Stewardship Contracting

Figure 2: Number of Stewardship Contracting Pilot Projects Expected to Be 

Completed Each Calendar Year through 2014

Notes: Of the 68 ongoing pilot projects, 52 provided an estimated completion date.

Data do not include two projects that were ongoing at the time of our survey but were expected to be 

completed in late 2003.

The pilot projects encompassed a variety of activities. For example, one 

project we visited—the Baker City Watershed Rehabilitation project—

involved thinning trees on Forest Service land that served as the watershed 

for an Oregon town. The water provided by the watershed was so pure that 

the town did not need a filtration facility, according to project and town 

officials. However, the watershed was at high risk for fire, which officials 

told us would degrade the watershed to the extent that a multimilliondollar treatment facility would be required. The watershed was thinned to 

reduce the density of fuels and thus the risk of fire, with the cost of logging 

partially offset by the value of timber removed. Logging was done by 

helicopter to avoid degrading the watershed by building roads. Figure 3 

shows a helicopter using a cable to lift and transport trees that were cut by 

workers on the ground.

0

2

4

6

8

10

12

2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014

11

8

4

7

6

4

5

2

0

2

1

Number of projects

Calendar year

Source: GAO.
Page 12 GAO-04-652 Stewardship Contracting

Figure 3: Helicopter Logging to Reduce Fuels at the Baker City Watershed 

Rehabilitation Pilot Project, Wallowa-Whitman National Forest

Another project we visited—the Burns Creek project in southwestern 

Virginia—involved cutting timber on Forest Service land and using an 

elevated cable harvesting system to transport the cut logs across a steep 

ravine to a sorting area, where they were stacked and sold. Forest Service 

officials decided against using a traditional logging approach because of 

the risk of environmental damage to the stream and drainage system in the 

ravine. After the timber was removed, the cable system was used to 

transport limestone to the creek at the bottom of the ravine to reduce the 

creek’s acidity. Project officials told us that without the cable system, the 

Forest Service would have had to spend considerably more money to 

transport the limestone to the creek by helicopter. Figure 4 shows the cable 

system used to transport timber and limestone on this project.

Source: Forest Service.
Page 13 GAO-04-652 Stewardship Contracting

Figure 4: Limestone to Be Added to a Creek to Reduce Acidity at the Burns Creek 

Pilot Project, George Washington-Jefferson National Forest

Across all stewardship contracting pilot projects, the most common 

activities were removing timber to improve forest health or reduce fuels 

and cutting slash, while other frequently cited activities included road 

maintenance and prescribed burning. Less commonly cited activities varied 

considerably and included culvert removal or installation; trail 

construction, maintenance, or obliteration; tree planting; wildlife pond 

restoration; and public toilet installation on national forest lands to protect 

water quality. Figures 5, 6, and 7 show additional examples of the types of 

activities undertaken as part of stewardship contracting projects.

Source: Forest Service.
Page 14 GAO-04-652 Stewardship Contracting

Figure 5: Mechanical Thinning at the Antelope Pilot Project, Fremont-Winema 

National Forests

Source: Forest Service.
Page 15 GAO-04-652 Stewardship Contracting

Figure 6: Prescribed Burning at the Antelope Pilot Project, Fremont-Winema 

National Forests

Source: Forest Service.
Page 16 GAO-04-652 Stewardship Contracting

Figure 7: Installation of Public Toilet at the Treasure Interface Pilot Project, Kootenai 

National Forest

In addition to these activities, several projects cited road construction, 

maintenance, or obliteration among their activities. In all, about 19 miles of 

permanent road are expected to be constructed as part of the pilot projects 

and another 292 miles reconstructed;14 conversely, 320 miles of permanent 

road are expected to be decommissioned (that is, closed and stabilized) 

and another 89 obliterated.

The stewardship contracting legislation enumerated seven land 

management goals. The goal most commonly cited by Forest Service 

project managers was removing vegetation or other activities to promote 

healthy forest stands, reduce fire hazards, or achieve other land 

management objectives; 59 projects reported addressing this goal to a great

14Permanent roads are those that are expected to remain part of the National Forest road 

system after their construction. In contrast, temporary roads are those built for a specific 

project and closed at the end of the project.

Source: Forest Service.
Page 17 GAO-04-652 Stewardship Contracting

or very great extent.15 Figure 8 shows the number of respondents reporting 

that their projects addressed the land management goals to a great or very 

great extent.

Figure 8: Number of Stewardship Contracting Pilot Projects Addressing Each Land 

Management Goal to a Great or Very Great Extent

Note: Sixty-five pilot projects reported their land management goals. Some projects reported more 

than one goal.

The stewardship contracting authority most commonly used to address 

these land management goals was goods for services, reported by 54 

projects. Least commonly used was supervision of marking and harvesting 

of timber sales, reported by only one project in Colorado, where the 

Colorado State Forest Service is administering the project contract. Figure 

9 shows the number of projects reporting the use of each authority.

15We asked respondents to indicate whether their project addressed each land management 

goal to a very great extent, great extent, moderate extent, some extent, or little or no extent.

0 10 20 30 40 50 60 70

Controlling noxious and exotic weeds and

reestablishing native plant species

Maintaining or obliterating roads and trails to restore

or maintain water quality

Setting prescribed fires to improve the composition,

structure, condition, and health of stands or to

improve wildlife habitat

Restoring and maintaining watersheds

Restoring and maintaining wildlife and fish habitat

Maintaining soil productivity, habitat for wildlife and

fisheries, or other resource values

Removing vegetation or other activities to promote

healthy forest stands, reduce fire hazards, or achieve

other land management objectives

Number of projects

Very great extent

Great extent

Source: GAO.

Land management goals
Page 18 GAO-04-652 Stewardship Contracting

Figure 9: Number of Stewardship Contracting Pilot Projects Reporting the Use of 

Each Stewardship Contracting Authority

Note: Sixty-six pilot projects reported their use of the authorities. Several projects used more than one 

authority.

0

10

20

30

40

50

60

Supervision of marking

and harvesting of

timber sales

Less than full and

open competition

Best-value

R

contracting

etention of

M

receipts

ultiyear

contracting

Designation by

description

Goods for

services

54

34 35 34

31

19

1

Source: GAO. 

Number of projects
Page 19 GAO-04-652 Stewardship Contracting

Pilot Projects Have Treated 

about 13,800 Acres and Are 

Expected to Treat about 

172,000 Acres in Total 

The sizes of the pilot projects (measured by the number of acres expected 

to be treated as part of each project) varied considerably, with the smallest 

project reported at 3.6 acres and the largest at 20,000 acres. The total 

reported acreage was about 172,000, with a mean project size of about 

2,600 acres. As figure 10 shows, slightly more than half of the projects 

involved less than 1,000 acres, while about 10 percent of the projects 

exceeded 10,000 acres.

Figure 10: Number of Stewardship Contracting Pilot Projects, by Project Size

Note: Sixty-six pilot projects reported their size.

But not all pilot projects had begun activities on the ground. Of the 77 

ongoing and completed pilot projects, 31 reported that some treatments 

had taken place. Only about 13,800 of the 172,000 acres expected to be 

treated under the pilot projects had been treated by the time of our survey. 

Among projects reporting some activity, the number of acres treated 

ranged from 8 to 3,224, with a mean of about 445 acres treated per project.

12 16

8

20

4

6

Less than 100 acres

100-499 acres

500-999 acres

1,000-4,999 acres

5,000-9,999 acres

10,000 acres or more

Source: GAO.
Page 20 GAO-04-652 Stewardship Contracting

Reported Project Costs, 

Revenues, and Products 

Varied Widely 

The expected costs of the projects differed markedly. The lowest reported 

total project cost was estimated at $1,000, while the highest was about $5.7 

million. The mean reported pilot project cost estimate was about $850,000. 

The portion of these costs attributed to contracts (that is, the amount paid 

to a contractor to perform services) also varied—from about $1,000 to $4 

million.16

Similar variation was evident in the expected value of products removed as 

part of the projects—primarily timber, but also firewood, wood chips, 

Christmas trees, and other products. The lowest estimate was $124, while 

the highest was about $6.3 million. These figures reflect the estimated value 

of material to be removed, without considering the contract costs required 

for its removal. The mean estimate of product value was about $480,000 per 

pilot project. 

Slightly more than half of the projects reporting both value and costs 

expected that contract costs would exceed product value—in other words, 

that the cost to pay a contractor to perform services would exceed the 

value of the materials to be removed. Of the 45 projects reporting both 

expected product values and expected contract costs, 24 (about 53 

percent) reported that expected contract costs would exceed expected 

product values. (The Forest Service may use appropriated dollars to pay 

contract costs not covered by product values.) The remaining 21 projects 

reported that expected revenues would equal or exceed expected contract 

costs. Overall, net revenue estimates (estimated product values minus 

estimated contract costs) ranged from a negative $3.27 million to $2.47 

million. 

16Contract costs are those paid by the Forest Service to a contractor and would not include 

other Forest Service costs, such as salaries or overhead, associated with planning and 

implementing projects. 
Page 21 GAO-04-652 Stewardship Contracting

Similarly, the amount of products to be removed varied among projects. 

The Forest Service’s standard unit of measure for wood products is 100 

cubic feet, or ccf. Thus, 100 cubic feet of wood would be measured as 1 ccf. 

Estimates of the volume of sawlogs (timber large enough to be milled into 

lumber) to be removed as part of stewardship contracting projects ranged 

from 0.7 ccf to 49,000 ccf. 17 About 70 percent of the reporting projects are 

expected to remove less than 5,000 ccf, and about one fourth are expected 

to remove less than 500 ccf. Estimates of other products (such as firewood 

and wood for posts and poles) varied from 4.2 ccf to about 67,000 ccf. Many 

projects also anticipated removing material of no commercial value, such 

as brush or small-diameter trees. Estimates of such noncommercial 

material ranged from 50 ccf to 144,000 ccf. Figures 11, 12, and 13 show 

examples of the material removed as part of stewardship projects.

17Not all survey respondents measured volume in ccf. Some used board feet, while others 

used tons. To facilitate conversion from board feet or tons to ccf, the Forest Service 

provided conversion factors for each measurement. However, a Forest Service official 

cautioned that these conversion factors are approximate, and that individual conversion 

factors are applied depending on product, species, and other factors. 
Page 22 GAO-04-652 Stewardship Contracting

Figure 11: Sawlogs at the Fernow Experimental Forest Pilot Project, Monongahela 

National Forest

Source: GAO.
Page 23 GAO-04-652 Stewardship Contracting

Figure 12: Firewood at the Seven Mile Pilot Project, Arapaho-Roosevelt National 

Forest

Source: Forest Service.
Page 24 GAO-04-652 Stewardship Contracting

Figure 13: Slash Pile at the Winiger Ridge Pilot Project, Arapaho-Roosevelt National 

Forest

Despite Limited Initial 

Guidance, Forest 

Service Has 

Incorporated 

Contracting and 

Financial Controls in 

Eight of Its Projects, 

and Both Forest 

Service and BLM Have 

Included Such Controls 

in Their Recent 

Guidance

The Forest Service limited the amount of initial contracting and financial 

guidance it provided to stewardship contracting pilot project officials to 

allow them to experiment with different approaches to managing the 

projects. Despite the limited guidance, the eight projects we visited had 

contracting and financial controls in place, including both preaward and 

postaward activities and controls to provide accountability in managing the 

projects (see fig. 14 for the projects’ names and locations). Since the 

enactment of the 2003 legislation expanding stewardship contracting 

authority, the Forest Service and BLM have developed more specific 

guidance on designing and implementing future projects and on accounting 

for project costs and revenues. 

Source: GAO.
Page 25 GAO-04-652 Stewardship Contracting

Figure 14: Locations of Stewardship Contracting Pilot Projects Visited during Our Review

Note: Names in parentheses are locations of the Forest Service offices conducting the projects.

Region 1

Northern

Region 5

Pacific Southwest

Region 10

Alaska

Region 6

Pacific Northwest

Sources: Forest Service and GAO.

1

1

2

2

3

3

4

4

5

5

6

6

7

7

8

8

Antelope (Chemult, Ore.) Winiger Ridge (Boulder, Colo.)

Baker City Watershed Rehabilitation (Baker City, Ore.) Wayah Contract Logging (Asheville, N.C.)

Warm Ridge/Glide (Idaho City, Idaho) Burns Creek (Roanoke, Va.)

Clearwater (Seeley Lake, Mont.) Fernow Experimental Forest (Parsons, W.Va.)

Puerto Rico

Region 4

Intermountain

Region 2

Rocky Mountain

Region 3

Southwestern

Region 9

Eastern

Region 8

Southern
Page 26 GAO-04-652 Stewardship Contracting

Initial Forest Service 

Contracting and Financial 

Guidance Was Limited, 

Slowing Implementation of 

Some Projects

The Forest Service provided limited initial contracting and financial 

guidance on stewardship contracting to allow project managers to 

experiment with different implementation approaches, according to an 

official with the Forest Service’s Forest and Rangeland Management 

Group. The Forest Service provided a “Desk Guide for Contracting under 

Existing Authorities for Service Contracts with Product Removal,” 

intended to provide guidance to field staff on conducting pilot projects, 

although the desk guide focused primarily on contracting authorities other 

than those in the stewardship legislation. Other guidance was provided by 

the Pinchot Institute for Conservation18—with which the Forest Service 

had contracted to review stewardship contracting implementation, 

including the design and management of monitoring, evaluation, and 

reporting processes. For example, the Pinchot Institute facilitated 

stewardship contracting workshops at Forest Service headquarters and 

several field locations to explain the nature of the stewardship contracting 

authority. The Pinchot Institute also provided technical assistance and 

general program guidance through its three subcontracted partners.19

Because of the limited guidance available to them, some project managers 

also sought project design assistance from staff in the Forest Service’s 

Northern Region, which had the greatest number of pilot projects and 

which had experience in and knowledge of stewardship contracting 

techniques.

Because of the lack of specific centrally issued guidance, some projects 

were slow to begin. Project managers attributed this delay to the need to 

independently determine how to design and implement their projects using 

their understanding of stewardship contracting and the need to coordinate 

the efforts of timber sale and acquisition contracting officers in developing 

a single contract. Under traditional contracts, timber sales are handled by 

timber sale contracting officers, while service acquisitions are handled by 

acquisition contracting officers. With the exchange of goods for services 

under stewardship contracting, only one contracting officer is needed for 

both activities; but close cooperation and coordination between the timber 

sale and acquisition offices are needed, which can be difficult and time 

18The Pinchot Institute for Conservation, located in Washington, D.C., is a nonprofit 

organization specializing in natural resource policy, research, and education.

19As part of its contract to assist the Forest Service in implementing and monitoring 

stewardship contracting, the Pinchot Institute hired three subcontractors to provide 

technical assistance and general program guidance regarding projects within their regions.
Page 27 GAO-04-652 Stewardship Contracting

consuming. For example, one contracting officer at the Antelope 

stewardship project said developing a contract combining a timber sale 

with various services took approximately 6 months, in contrast to the 

approximately 2 to 3 months that this official said were required for a 

standard timber sale or service contract. This official told us the delay 

occurred primarily because of the lack of direction on how to achieve the 

necessary coordination between the timber sale and acquisition 

contracting offices.

Projects We Visited 

Incorporated Both 

Preaward and Postaward 

Contracting Controls

The eight projects we visited generally included the preaward and 

postaward contracting activities and safeguards we believe are necessary 

for effectively awarding and administering stewardship contracts. 

Preaward controls we looked for included widely distributed contract 

solicitations, the use of pre-established criteria for evaluating bids, and 

meetings with potential contractors to clarify project activities and Forest 

Service expectations. Postaward controls we looked for included the use of 

payment or performance bonds, appropriate techniques for valuing forest 

products, and provisions for on-the-ground inspections of contractor work. 

See appendix II for more information about our selection of these criteria.

Projects Used Various Preaward 

Controls

The project managers for the projects we reviewed undertook preaward 

solicitation and advertisement activities to seek contract bids and 

proposals. These efforts included solicitations in the form of mailings to 

potential contractors, advertisements in local newspapers, and national 

announcements in the Commerce Business Daily and on the Federal 

Business Opportunities Web site.20 Such solicitations are intended to 

maximize the number of potential contractors aware of the project, and 

thus the pool of potential bidders. When solicitations did not result in any 

bidders, the solicitations were sometimes expanded to include a broader 

geographic area. The project managers also held conferences with 

potential contractors before they submitted bids or proposals, and 

sometimes potential contractors made trips to the proposed project sites. 

These “scoping” sessions served to clarify project objectives and contract 

20The Commerce Business Daily and the Federal Business Opportunities Web site 

(http://www.FedBizOpps.gov) list notices of proposed government procurement actions, 

contract awards, sales of government property, and other procurement information. As of 

October 1, 2001, all federal procurement offices are required to use FedBizOpps to 

announce proposed procurement actions and contract awards if they are over $25,000 and 

are likely to result in the award of a contract to a subcontractor.
Page 28 GAO-04-652 Stewardship Contracting

terms and schedules, as well as to solicit ideas from contractors and to 

increase local awareness of projects. Project managers and other agency 

staff also conducted bid reviews using predefined criteria to ensure 

thoroughness and objectivity in evaluating each bid and awarding the 

contracts. The evaluation criteria included such factors as bidders’ past 

performance and experience, proposed work schedules and technical 

approaches, and cost or price factors. The Forest Service evaluation teams 

generally were composed of experienced contracting officers, project 

managers, and other key Forest Service staff.

Awarded Contracts Generally 

Included Bond, Valuation, and 

Inspection Requirements to 

Provide Accountability in Project 

Management

Contracts for the eight projects we visited generally incorporated 

safeguards such as bond, valuation, inspection, and default requirements. 

The contracts we reviewed contained clear definitions of contract 

requirements, including work-site locations, access points, and the size of 

work units. The contracts also generally defined the roles of the various 

Forest Service staff, including those responsible for oversight activities, 

such as the contracting officers and the contracting officers’ 

representatives. Before commencing work under the contract, Forest 

Service project managers generally held orientations with the contractors 

to clarify contract terms, work performance requirements, and work 

progress schedules. These meetings sometimes resulted in amendments to 

the solicitations and clearer contract language. 

Nearly all of the stewardship contracts we reviewed included payment and 

performance bond clauses to ensure the satisfactory performance of 

contract requirements. These bonds are written instruments executed by 

the contractor to ensure fulfillment of its obligations. If the obligations are 

not met, the bonds ensure payment, to the extent stipulated, of any loss 

sustained. In particular, payment bonds, also known as advance deposits or 

cash deposits, ensure that the government receives payment for timber 

harvested. In the event that a contractor harvests timber but then defaults 

on the contract or goes out of business before paying for it, the agency can 

keep the cash value of the bond as payment for the timber. Similarly, 

performance bonds ensure that, in the event the government is required to 

conduct work to remediate damage done by the contractor, the agency can 

use the value of the performance bond to finance remediation activities. 

Although most contracts included bonds, some did not. The Winiger Ridge 

Restoration project, for example, did not include payment or performance 

bonds. The project manager told us that she believed such bonds were too 

onerous for small contractors, and agency officials wanted to make the 

project as attractive as possible to small local contractors. Additionally, 

according to the project manager, there was little incentive for the 
Page 29 GAO-04-652 Stewardship Contracting

contractor to cut commercially valuable timber and then default on the 

remainder of the services because there was very little valuable timber 

included in the project. This manager characterized the contract as 

“$190,000 worth of services and $500 worth of timber.” Another project—

Antelope—did not require a performance bond because of the expense and 

burden it would place on the contractor, according to the project manager. 

The stewardship contracts also included valuation clauses to establish the 

volume and value of the forest materials to be removed and the services to 

be provided. Volume is determined by a “cruise” of the project area, which 

involves staff examining the area in different locations to estimate the 

timber that is to be removed. Forest Service managers at the projects we 

examined established the value of timber through government cost 

estimates or appraisals. Government cost estimates are simply indications 

of what the timber will bring on the market based on previous sales, 

according to Forest Service staff. Appraisals, on the other hand, involve 

calculations of not only what the timber will bring on the market but also 

the cost of cutting and hauling the timber, constructing or improving roads, 

and so forth, and are thus more detailed, time consuming, and expensive. 

According to staff, government cost estimates are appropriate when the 

value of the material is known to be low, because in such cases the cost of a 

full appraisal can exceed the value of the material. Of the eight projects we 

reviewed, five conducted full appraisals while three used government cost 

estimates.21

The stewardship contracts we examined also included provisions for onthe-ground inspections of contracted work to ensure that the work was 

conducted in accordance with contract requirements and Forest Service 

expectations. At the projects we reviewed, the contracting officers and the 

designated contracting officers’ representatives who served as on-theground administrators documented their observations on inspection forms 

and contract daily logs, which we examined. These logs included 

information on whether the work was performed in an acceptable manner, 

and the measures necessary to correct any deficiencies. 

Additional effort was sometimes required to ensure that contractors 

performed according to Forest Service expectations. For example, the 

Winiger Ridge Restoration stewardship project contracting officer told us 

21Although we determined that appraisals or estimates were conducted, we did not review 

these appraisals or estimates for accuracy.
Page 30 GAO-04-652 Stewardship Contracting

that the project’s initial contract had to be revised to make the designation 

by description specifications clearer to the contractor, after it became 

evident that the specifications as written did not lead to the expected 

results. (Designation by description allows the agency to conduct a timber 

harvest by providing the contractor with a description of the trees to be cut 

or the desired end result of the harvest, rather than by marking individual 

trees.) At this project, the initial description directed the contractor to, 

among other things, cut all trees with a certain level of dwarf mistletoe 

infestation.22 However, project officials realized that it was impossible to 

verify that the contractor had cut only infected trees, and contract 

provisions regarding mistletoe infestation were eliminated. Similarly, 

contracting officers and contractors at other locations also told us that the 

contractors sometimes had difficulty interpreting the language in 

designation by description contracts, or that the language was not specific 

enough to ensure that Forest Service expectations were met. This unclear 

language sometimes required additional project oversight to ensure that 

contractors were meeting contract requirements. At the Clearwater 

stewardship project, for example, the project manager told us that although 

they had planned periodic project inspections, the use of designation by 

description authority required them to have inspectors on site virtually 

every day for several weeks.

Finally, the stewardship contracts we reviewed also included breach or 

default and dispute resolution clauses. These mechanisms allow the Forest 

Service to address any issues or problems by issuing default notices and 

stop work orders. However, aside from work delays, which generally 

resulted from uncontrollable events such as excessive snow or fire 

seasons, there were no significant problems with the contracts we 

examined. In fact, several Forest Service contracting officers we 

interviewed praised the relative ease of administering the contracts once 

they were developed and awarded. Similarly, the contractors conducting 

the work told us that, although the stewardship contracts and the 

contracting process were somewhat new and time consuming to them, 

implementation of the contracts themselves was relatively straightforward.

22Dwarf mistletoe is a small, seed-bearing parasitic plant that infects several tree species. 

According to USDA, the infection causes increased mortality, reduced growth rates, loss of 

vigor, lowered timber quality, and reduced seed production.
Page 31 GAO-04-652 Stewardship Contracting

We Observed Established 

Financial Procedures at the 

Projects We Visited

During our project site visits, we observed evidence of established 

procedures in place for accounting for project funds, including procedures 

for receiving and tracking timber payments and tracking retained receipts 

and expenditures, as well as other steps taken to provide financial 

accountability. Our review of selected items included an examination of 

payment vouchers, receipts, and other expenditure-related documentation 

to assess whether retained receipts and other project funds had been spent 

on stewardship-related activities. We did not review all financial controls 

for stewardship contracting. 

The Forest Service uses two data collection systems—the Timber Sale 

Accounting (TSA) system and the Foundation Financial Information 

System (FFIS)—to track project financial activities. The TSA tracks data 

such as the name of the purchaser and the quantity and species of timber to 

be harvested, and is the principal system for recording revenues related to 

timber sales. However, the TSA reflects only a portion of stewardship 

contracting activity. While the TSA includes timber-specific information 

such as species, it does not reflect the services contracted for as part of 

stewardship contracting projects; instead, these services are recorded and 

tracked at the local forest or regional office. The FFIS, which incorporates 

some TSA data, is the system of record supporting Forest Service billing 

and collection functions. As with traditional timber sale contracts, actual 

payments are received and processed through an independent “lockbox” 

system in San Francisco.23 The payment receipts are recorded by job code 

in a specified distribution account within the FFIS. 

At each location, we observed adequate separation of duties and 

supervisory review responsibilities being handled by officials in the timber 

and financial groups. For example, a project official at each location was 

responsible for verifying the accuracy of all the charges to the project 

account, and the financial group manager was responsible for monitoring 

the project account balances. At the end of each month, timber and 

accounting clerks completed reconciliations between the timber and 

financial system data and their detailed local records. When discrepancies 

were identified, the problems were researched and corrected in a timely 

manner. For those projects we looked at, several monthly reports were 

generated by the TSA and FFIS systems, which managers in each group 

23Lockbox banks establish post office boxes or electronic accounts to receive payments 

made to federal agencies. The banks then transfer the funds to the Treasury and submit 

collection reports to the agencies.
Page 32 GAO-04-652 Stewardship Contracting

used to track project activities and to review and verify the accuracy of the 

charges against project funds.

Two projects we visited, the Clearwater and Fernow Experimental Forest 

projects, had expended retained receipts on additional stewardship 

contracting activities. At these projects, we examined payment vouchers, 

receipts, and other expenditure-related documentation to ensure that 

retained funds had been spent on stewardship-related activities, as 

required, and the funds appeared to have been spent appropriately. Another 

project we visited, the Burns Creek project, passed all retained receipts on 

to another stewardship project, the Wayah Contract Logging project, in the 

same region; however, the Wayah Contract Logging project (which we also 

visited) did not need to use the funds because receipts and appropriated 

funds associated with that project were sufficient to cover project 

expenditures. As a result, the retained receipts were being passed on yet 

again to a third stewardship project, the Sand Mountain project, also in the 

same region. At the time of our review, a portion of these funds had been 

obligated to cover the cost of a contract for work on this project, but had 

not yet been expended. 

Forest Service staff at the locations we visited took additional steps to 

provide financial accountability. For example, we noted procedures in 

place to prevent timber harvesting activities from significantly exceeding 

service activities under goods for services contracts. To this end, two 

projects (the Clearwater and Warm Ridge/Glide projects) established “land 

management credits” to record service activities completed. Once the 

contractor earned such credits, they were then applied to the value of the 

timber being harvested. At these projects, contractors were not permitted 

to harvest timber until they had earned the required credits through service 

work—thus preventing contractors from harvesting commercially valuable 

timber and then failing to perform needed restoration activities. 

Forest Service and BLM 

Recently Developed 

Stewardship Contracting 

Guidance That Includes 

Contracting and Financial 

Controls

The Forest Service and BLM issued jointly developed guidance in January 

2004 to provide direction in implementing stewardship contracts. The 

Forest Service’s new handbook and BLM’s new guidance address the use of 

contracting controls, such as appraisals, and the use of two authorities—

designation by description and less than full and open competition; include 

contract templates for field staff; provide guidance on financial 

accountability; and outline the responsibilities of agency staff. According to 

an official with the Forest Service’s Forest and Rangeland Management 

Group, their handbook is intended to be a working document that will 
Page 33 GAO-04-652 Stewardship Contracting

change as necessary. For example, if the results of ongoing monitoring of 

stewardship contracting show a need for changes, the handbook will be 

revised accordingly.

The agencies’ guidance includes some of the same elements we examined 

during our site visits to provide project accountability. For example, both 

agencies’ guidance includes provisions requiring appropriate valuation of 

service work to be performed and timber to be harvested. To this end, the 

Forest Service handbook states, “The appraisal for timber and other forest 

products shall be conducted using appraisal methods as specified in the 

Timber Sale Preparation Handbook . . . and Regional guidelines.” Both 

agencies also provide guidance on required bonding. For example, the BLM 

guidance states that “payment protection in the form of payment bonds 

should be used to protect the value of the byproduct to be removed when 

the product will be removed prior to cash payment or the contractor’s 

earning of conservation credits.” BLM’s guidance further states that 

“contracting officers are encouraged to strive toward the concept of a 

single bond to cover ‘performance,’ which would include the product value 

(payment) and the service work rolled into one bond.”

The agencies’ guidance also provides expanded discussions on the use of 

two additional authorities—designation by description and less than full 

and open competition. Regarding designation by description, the guidance 

specifies that the amount of material removed from the forest must be 

verifiable and accountable. For example, the Forest Service handbook 

generally requires that for commercial material (such as sawtimber), trees 

to be removed must be identified based on characteristics that can be 

verified after removal—for example, the contractor might be required to 

remove all lodgepole pine less than a specified stump diameter. Agency 

personnel could subsequently measure remaining stumps to verify that 

contract provisions were met. For noncommercial material, the handbook 

allows less specific designations setting forth the desired end result of 

treatment (sometimes referred to as designation by prescription)—for 

example, the contractor might simply be required to leave a certain number 

of trees on each acre, with an average spacing between them.

Regarding less than full and open competition, which exempts the agency 

from the requirement that all sales of timber having an appraised value of 

$10,000 or more be advertised, the Forest Service handbook specifies that 

forest supervisors must document and submit to regional foresters the 

reasons for the selection process used. Documentation must include the 

level of competition to be used in the contracting process.
Page 34 GAO-04-652 Stewardship Contracting

As part of their guidance, the agencies also are developing contract 

templates that field staff can use as examples when developing their own 

contracts—potentially improving the efficiency and applicability of 

stewardship contracts. These are standard contract formats that 

incorporate timber sale and service components. The Forest Service has 

also conducted additional training sessions, and staff from both agencies 

told us they plan to expand their intranet sites to provide more ongoing 

stewardship contracting project information, including details about 

successful stewardship contracting projects that can serve as models for 

staff who are developing projects. 

The agencies’ guidance also contains direction on financial accountability. 

According to the Forest Service handbook, the proper use and 

management of stewardship contracting receipts must be assessed as a 

normal part of regional- and forest-level renewable resource program and 

activity reviews. Through the guidance, both agencies have assigned 

responsibility for various financial activities, including providing technical 

advice, reviewing and approving retention of project receipts, and ensuring 

that associated financial data are accurate and reconciled to the financial 

statements. In addition to specifying responsibility for various activities, 

the agencies’ guidance notes the approved funding source for projectrelated activities. For example, stewardship contracting preparation, 

overhead, and project-level monitoring costs normally are to be funded 

through appropriated funds. According to the guidance, stewardship 

contracting retained receipts shall not be used for overhead, 

administrative, or indirect costs or for the completion of environmental 

studies. The guidance indicates these retained receipts can be used for 

another stewardship project or to fund national programmatic multiparty 

monitoring. Although both agencies’ guidance states that multiparty 

monitoring of individual projects is encouraged, the Forest Service 

handbook states that it is inappropriate to conduct project monitoring with 

revenues received from a stewardship contract.

Finally, both agencies’ guidance outlines the responsibilities of the various 

headquarters, regional, and state office officials in the implementation, 

monitoring, and evaluation of stewardship contracting projects. The 

agencies also have appointed stewardship contracting coordinators at each 

Forest Service regional office and at each BLM state office. These staff 

serve as resources for all projects under the respective Forest Service 

regional offices and BLM state offices and are expected to enhance 

communication between the agencies’ headquarters and the field. Their 

specific responsibilities include clarifying stewardship contracting 
Page 35 GAO-04-652 Stewardship Contracting

guidance, monitoring project status and soliciting feedback, and making 

recommendations on how to improve the effectiveness of stewardship 

contracting.

The Agencies Have Not 

Provided Substantial 

Guidance on 

Community 

Involvement, and 

Efforts to Involve 

Communities Varied 

among Projects

Despite the stewardship contracting legislation’s emphasis on meeting 

community needs, the Forest Service initially provided little guidance on 

incorporating community involvement in stewardship contracting pilot 

projects; as a result, the type and extent of field staffs’ efforts to involve 

communities in projects varied considerably among the projects we 

reviewed. Some project managers actively sought community involvement 

in planning or implementing their projects, while other managers took a 

less active approach—potentially leading to missed opportunities for 

meeting local community needs. Although the majority of the project 

managers we spoke with touted the potential benefits of community 

involvement in stewardship contracting projects and expressed their desire 

for additional guidance in this area, neither the Forest Service nor BLM 

included such guidance in their January 2004 stewardship contracting 

guidance documents. 
Page 36 GAO-04-652 Stewardship Contracting

Because the Forest Service 

Initially Provided Little 

Guidance on Community 

Involvement, the Type and 

Extent of Community 

Involvement Varied 

Significantly among 

Projects

Although the stewardship contracting legislation explicitly stated that 

stewardship projects are “to achieve land management goals for the 

national forests that meet local and rural community needs,” the Forest 

Service initially provided only minimal guidance on soliciting and 

incorporating community involvement in stewardship contracting projects, 

and most managers we spoke with articulated their frustration with the 

overall lack of guidance on community involvement. Managers told us that 

little or no formal training on involving the community had been provided, 

and in some cases reported that the only guidance they had received was in 

the form of a brief discussion of the topic during a meeting. The most 

frequently identified source of community involvement guidance was in the 

form of advice from the Pinchot Institute for Conservation’s regional 

subcontractors, which reportedly provided some consultation on 

community involvement efforts. The managers’ desire for guidance or 

training resulted primarily from two concerns: first, that they were wasting 

time “reinventing the wheel” because they were unaware of effective or 

innovative community involvement strategies developed by managers of 

other projects, and second, that they were potentially violating the Federal 

Advisory Committee Act (FACA) by incorporating community involvement 

into their projects.24

Because of the lack of guidance, the steps taken by Forest Service 

managers to involve communities varied widely. Most of the community 

involvement we learned about was incorporated through multiparty 

monitoring teams, which were required by the stewardship contracting 

legislation. However, the legislation did not specify, and the Forest Service 

provided little guidance on, the teams’ roles and responsibilities, leading to 

uncertainty among field staff about what was expected and how to 

proceed. Some projects simply did not have monitoring teams, and some 

managers told us they did not realize such teams were required. The 

project managers who assembled monitoring teams did so using very 

different approaches. For example, some managers formed teams of 

primarily Forest Service employees, while others sought to involve a cross 

section of the community. The Yaak project manager in Montana even 

transferred the responsibility for assembling the project monitoring team 

and completing an annual report on the project to the contractor, by 

24The Federal Advisory Committee Act was enacted in 1972. (See Pub. Law No. 92-463, 86 

Stat. 770, 5 U.S.C. app 2.) Among other things, the act requires advisory committee meetings 

to be open to the public and requires detailed minutes of each meeting to be kept and made 

publicly available. (See 5 U.S.C. app 2, § 10.)
Page 37 GAO-04-652 Stewardship Contracting

making these efforts a requirement in the contract. Some managers formed 

small teams composed of a few interested local individuals, while the 

manager at the Priest-Pend Orielle project in Idaho formed a large 

monitoring team consisting of about 30 members organized into several 

specialized subcommittees focusing on specific issues such as roads, 

watershed, wildlife, and noxious weeds. This project manager also 

coordinated with the team to ensure that a Forest Service specialist was 

available to consult with each of the subcommittees as needed. 

The project monitoring teams also played varying roles and undertook 

varying activities. Team members included university professors, local 

government officials, environmental advocates, industry representatives, 

and other interested citizens, and the composition of the team often helped 

to determine the level and type of work the team undertook. For example, 

several project managers noted that their teams focused on assessing the 

effectiveness of specific ecological work or evaluating the project’s impact 

on the local economy, while other teams focused on assessing the 

stewardship contracting process, believing that their assessment of the tool 

would help the Congress evaluate the pilot program. The monitoring teams 

conducted such activities as inspecting project sites, testing soils and 

water, establishing photo points,25 and gathering and analyzing economic 

information. Figure 15 shows a multiparty monitoring team meeting at a 

project site.

25Photo points are vantage points from which before and after pictures are taken in order to 

document visual changes to a project site.
Page 38 GAO-04-652 Stewardship Contracting

Figure 15: Multiparty Monitoring Team Reviewing Project Site at the Clearwater Pilot 

Project, Lolo National Forest

In a few instances we noted other forms of community involvement. Some 

managers took steps such as meeting with local contractors and 

environmentalists to hear their concerns and answer questions, or setting 

up demonstration areas that would show local residents how the project 

site would look once the work was done. However, such steps were not 

common, and in fact some managers told us that the NEPA process alone 

allows for sufficient public participation in their projects.26 They said that 

as a result—and without guidance to the contrary—they did not feel that 

additional efforts to involve communities were necessary or justified. In 

fact, one Forest Service official at the Burns Creek project site in Virginia 

told us that management of the forest might be better left to forestry 

26For major federal actions that may significantly affect the quality of the human 

environment, the National Environmental Policy Act requires all federal agencies, including 

the Forest Service and BLM, to analyze the potential environmental effects of the proposed 

action. (See 42 U.S.C. 4332(2)(C).) Regulations implementing NEPA require agencies to 

involve the public in environmental decision making by, among other things, making draft 

environmental reviews available to the public for comment. (See 40 C.F.R. 1506.6(b).)

Source: Forest Service.
Page 39 GAO-04-652 Stewardship Contracting

professionals than to a collaborative group of well-meaning—but 

untrained—community members.

Many Agency Officials 

Believe Collaboration 

Enhances Project 

Effectiveness and Provides 

Other Benefits 

Some project managers may be missing opportunities to improve their 

projects, as the majority of the project managers we spoke with touted the 

benefits of involving the community in stewardship contracting projects. 

Although some project managers noted that community involvement 

activities require an additional investment of time and effort upfront, 

several believe that this effort will pay off in the end.

Project managers cited a variety of benefits from community involvement, 

including improved project design and implementation, better lines of 

communication with the public, and enhanced public trust in the agencies. 

Several project managers indicated that they valued the project monitoring 

teams’ expertise and input, and some noted improvements to their projects 

as a result of team and other community input. For example, the manager 

of the Upper Blue project in Colorado told us that public involvement in 

her project led to the development of more stringent criteria for protecting 

water quality during project activities. The Main Boulder project manager 

in Montana told us that public involvement in his fuels reduction project 

led to improved relations with the public, which in turn persuaded a 

neighboring landowner to offer the agency access across his land to an 

isolated parcel of public land needing fuel reduction. This allowed the 

manager to add an additional 40 acres to the project’s planned fuel 

reduction activities.

Some managers viewed their interaction with the project monitoring team 

as an opportunity to get back in touch with the community and improve the 

agency’s credibility, and some sought to involve a cross section of the 

community—including environmentalists and loggers—on their monitoring 

teams to improve the agency’s relationship with the community. The 

manager of the Sheafman Restoration project in Montana said she wanted a 

cross section of the community on her project’s team because she believes 

“any time you can get people from different sides of an issue together to 

talk, good things happen.” The Priest-Pend Orielle project manager 

observed that in his community—as in so many others—the Forest Service 

had lost touch with the local community. He sees tremendous benefits in 

the agency’s new collaboration process with the community, and suggested 

the agency will have greater opportunities to build credibility with the 

community on future projects because local individuals have seen the 

agency responding to their input. The manager of the Red-Cockaded 
Page 40 GAO-04-652 Stewardship Contracting

Woodpecker Habitat project in Georgia told us that by attending the 

meetings of other community organizations and taking an active interest in 

what those groups are doing, she has improved communications with the 

community—leading to increased public input on Forest Service projects, 

which in turn helps the agency better focus its projects to meet community 

needs. 

However, benefits were often limited because most of the monitoring 

teams were formed after the projects completed NEPA requirements, 

meaning that these teams generally participated only during the 

implementation phase of the projects rather than during project design. 

Several project managers suggested that stewardship contracting projects 

could be more effective if the community were brought to the table during 

the earliest project discussions to assist in drafting proposals of needed 

work.

Neither Agency’s 2004 

Guidance Clarifies How 

Community Involvement 

Should Be Incorporated 

Despite the many project managers who told us they wanted additional 

guidance on obtaining and incorporating community involvement, the 

Forest Service’s recent stewardship contracting handbook does not contain 

specific guidance in this area, and BLM’s guidance document is similarly 

lacking. In commenting on a draft of this report, Forest Service officials 

noted that the agency’s intent was to allow local agency officials the 

flexibility to determine the appropriate level of collaboration for their 

communities. Although the agencies’ 2004 guidance documents repeatedly 

mention “community involvement” and “collaboration,” they do not specify 

what these terms mean or how agency staff are to accomplish them. For 

example, the Forest Service handbook indicates that forest supervisors 

should ensure that all stewardship contracting projects are developed 

“using collaboration with Tribal governments, local governments, 

nongovernment organizations, individuals, and other groups, as 

appropriate.” However, the handbook neither provides guidance on how to 

effectively involve these various groups and individuals nor defines 

“appropriate” collaboration. (In contrast, the handbook’s guidance on 

contracting and financial activities includes defined lists of appropriate and 

inappropriate activities.) In fact, the closest either guidance document 

comes to saying what form this collaboration should take is a statement 

about what collaboration is not. According to the Forest Service handbook, 

“The use of scoping letters alone does not meet the intent of collaborative
Page 41 GAO-04-652 Stewardship Contracting

efforts for stewardship contracting projects.”27 Moreover, while the 

Consolidated Appropriations Resolution of 2003 eliminated the 

requirement for multiparty monitoring teams to assess each project, it did 

not specify what form of community involvement should take its place. 

Project managers are concerned that without guidance on best practices 

from other projects, they may be inefficiently developing community 

involvement mechanisms independently. Guidance on the minimum 

requirements for community involvement in each stewardship project, 

including examples of best practices, could increase both the efficiency of 

managers’ efforts and the extent of community involvement in the projects. 

By providing more definitive guidance, the Forest Service and BLM could 

reasonably expect to enhance the effectiveness of stewardship contracting 

and more fully realize its potential. 

Both Agencies Have 

Additional Projects 

Planned and Intend to 

Assess the 

Effectiveness of 

Stewardship 

Contracting 

Both the Forest Service and BLM plan to use stewardship contracting in the 

future. The Forest Service expects to award at least 67 stewardship 

contracts in fiscal year 2004. BLM, which was granted stewardship 

authority only in 2003, has begun 2 projects and plans about 34 more in 

fiscal year 2004. The agencies did not provide specific data for years 

beyond 2004, but agency officials said they intend to continue expanding 

the use of stewardship authority in the future. According to Forest Service 

and BLM officials, both agencies plan to collect information on 

stewardship contracting projects to assess the utility of stewardship 

contracting relative to other contracting mechanisms.

Both Agencies Plan 

Additional Use of 

Stewardship Authority in 

Fiscal Year 2004

According to an official with the Forest Service’s Forest and Rangeland 

Management Group, the agency awarded 49 stewardship contracts in fiscal 

year 2003 and 7 more as of March 2004, and expects that an additional 60 or 

more contracts may be awarded during the remainder of fiscal year 2004. 

However, the Forest Service does not track the authority under which it 

awards stewardship contracts, and as a result the agency could not 

determine how many of these contracts pertain to new projects and how 

many pertain to the 77 pilot projects we analyzed.

27Scoping letters, an element of the NEPA process, request comments, questions, and 

suggestions from interested parties on the scope of issues to be addressed in the NEPA 

analysis. (See 40 C.F.R. 1501.)
Page 42 GAO-04-652 Stewardship Contracting

BLM has begun two stewardship contracting projects, both in Oregon. One 

project, in Applegate, is expected to be completed in 2004; the other, near 

Baker City, does not yet have an estimated completion date. Two additional 

projects—one in Idaho and one in Utah—are being developed, and two 

more (one in California and one in Oregon) have been approved. BLM plans 

to begin about 30 additional projects in fiscal year 2004.

Both Agencies Plan to 

Assess the Use of 

Stewardship Contracting 

Each agency’s recent guidance contains provisions for monitoring and 

assessing the use of stewardship contracting, and agency officials told us 

that monitoring and assessment serve two purposes—they enable the 

agencies to provide information both to the Congress on stewardship 

contracting and to field staff responsible for stewardship contracting 

projects. BLM’s guidance states that “one objective of this monitoring effort 

is to analyze the effectiveness of stewardship contracting relative to other 

management tools.” The Forest Service’s handbook states that “results 

from the longer term programmatic monitoring generate information about 

the utility of stewardship contracting authority.” 

Officials with both agencies told us that the results of the monitoring will 

be used to construct the agencies’ required annual reports to the Congress 

on stewardship contracting. The agencies are required to report on the 

status of development, execution, and administration of stewardship 

contracts; the specific accomplishments that have resulted; and the role of 

local communities in development of contract plans. Officials also told us 

that the results of the monitoring will be provided to agency field staff to 

assist staff in designing and implementing projects. For example, a Forest 

Service official told us that information on both successful and problematic 

projects would be shared with field staff to help them determine whether 

certain types of projects are more suitable for stewardship contracting than 

others, or whether certain stewardship contracting procedures are more 

effective than others in certain situations. 

To carry out their monitoring efforts, the agencies are jointly developing a 

request for proposal for a contractor to develop and implement a 

mechanism for monitoring and evaluating stewardship contracting 

projects. Agency officials estimated that the request would be issued in 

spring 2004 and expect to issue a single monitoring contract covering 

stewardship contracting projects in both agencies.
Page 43 GAO-04-652 Stewardship Contracting

Conclusions As the Forest Service and BLM undertake projects to achieve land 

management objectives—particularly their efforts to reduce fuels under 

the Healthy Forests Restoration Act—they are likely to rely increasingly on 

stewardship contracting. This tool has the potential to help the agencies 

achieve their objectives while meeting community needs. Community 

involvement is a critical component of stewardship contracting: It enables 

the agencies not only to construct projects that are targeted toward 

community needs but also to develop community relationships, thereby 

enhancing future efforts to collaborate with communities.

However, while we observed contracting and financial controls in place 

that we believe will provide accountability in managing projects, we 

believe that the agencies could do more to assist individual project 

managers as they seek to incorporate public involvement in their projects. 

Community involvement in the pilot projects most often took the form of 

multiparty monitoring teams, but these teams are no longer required for 

each stewardship project, and neither agency provides substantive 

guidance on incorporating community involvement. Many Forest Service 

project managers said they wanted more guidance in this area, but 

managers looking to the agencies’ 2004 stewardship contracting guidance 

for direction on community involvement will likely find little of use. Unless 

the agencies establish a minimum requirement for community involvement 

in stewardship projects (to replace the expired requirement for monitoring 

teams) and provide project managers with examples of successful 

community involvement practices other projects have used, the agencies 

may fail to capitalize fully on the potential of stewardship contracting. 

Recommendation for 

Executive Action

To enhance the ability of stewardship contracting projects to meet local 

needs and improve public trust in the agencies, we recommend that the 

Secretaries of Agriculture and the Interior direct the agencies to issue 

additional guidance on community involvement. Such guidance should 

identify, and encourage the use of, best practices in seeking and 

incorporating community input, and establish minimum requirements for 

seeking community involvement on each stewardship contracting project.

Agency Comments and 

Our Evaluation

We provided a draft of this report to the Secretaries of Agriculture and the 

Interior for review and comment. The Forest Service generally agreed with 

our report and provided technical suggestions that we incorporated, as 
Page 44 GAO-04-652 Stewardship Contracting

appropriate. The Forest Service’s comment letter is presented in appendix 

IV. The Department of the Interior did not provide comments.

We are sending copies of this report to the Secretary of Agriculture, the 

Secretary of the Interior, the Chief of the Forest Service, the Director of 

BLM, and other interested parties. We will also make copies available to 

others upon request. In addition, this report will be available at no charge 

on GAO’s Web site at http://www.gao.gov.

If you or your staff have any questions about this report, please contact me 

at (202) 512-3841. Key contributors to this report are listed in appendix V.

Barry T. Hill

Director, Natural Resources and Environment
Page 45 GAO-04-652 Stewardship Contracting

List of Requesters

The Honorable Tom Harkin

Ranking Democratic Member

Committee on Agriculture, Nutrition, and Forestry

United States Senate

The Honorable Nick J. Rahall II

Ranking Minority Member

Committee on Resources

House of Representatives

The Honorable Jay Inslee

Ranking Minority Member

Subcommittee on Forests and Forest Health

Committee on Resources

House of Representatives

The Honorable Jeff Bingaman

United States Senate

The Honorable Maria Cantwell

United States Senate

The Honorable Patrick J. Leahy

United States Senate
Page 46 GAO-04-652 Stewardship Contracting

Appendix I

Forest Service’s Responses to Apendxies

Environmentalists’ Concerns about Projects 

Identified as Problematic ApendxiI

As requested, we reviewed six stewardship contracting pilot projects 

identified as problematic by members of various environmental groups: the 

Buck, Hungry Hunter Ecosystem Restoration, and Sprinkle Restoration 

projects in the Forest Service’s Pacific Northwest Region; the Meadow 

Face and North Fork Big Game Habitat Restoration projects in the 

Northern Region; and the Granite Watershed Protection and Enhancement 

project in the Pacific Southwest Region. According to the environmental 

group members, these projects either did not allow for sufficient public 

involvement or adversely affected the environment in some way.

Four of the six projects were cited for insufficient public involvement, 

which took the form of limited public input or lack of Forest Service 

commitment and support, according to environmental group members we 

spoke with. Ecological concerns were raised about several projects and 

included impacts on wildlife habitat and water quality, high road densities, 

and soil compaction, as well as the perceived failure of the Forest Service 

to consider all costs and benefits in its project analyses, including impacts 

on local communities and big-game habitat. The Forest Service project 

managers we interviewed generally agreed that public involvement was 

lacking at the four projects where this was cited as a concern. However, 

their responses to environmental concerns varied.

In this appendix, we provide, for each of the six projects, a description of 

the project, a discussion of the concerns expressed by environmentalists, 

and the Forest Service’s responses to those concerns. We do not take a 

position on the validity of the concerns or responses.

Buck Pilot Project The Buck project is located in Oregon’s Wallowa-Whitman National Forest 

in the Forest Service’s Pacific Northwest Region. It was designed as a 

timber sale in 1998 before the initial stewardship contracting legislation 

was enacted. The project was subsequently altered to incorporate activities 

to reduce wildfire risk and was completed in 2004.

Environmental Group Concerns According to a member of the Hell’s Canyon Preservation Council (HCPC), 

a local environmental group, HCPC was generally concerned about the lack 

of public input in the project’s design and implementation and about the 

lack of restoration activities. Specifically, this HCPC member told us the 

project was simply a repackaged timber sale that was not planned or 

designed with up-front community involvement beyond that required as 

part of the National Environmental Policy Act (NEPA) process, which the 

member did not consider a substitute for true local collaboration. Further, 
Appendix I

Forest Service’s Responses to 

Environmentalists’ Concerns about Projects 

Identified as Problematic

Page 47 GAO-04-652 Stewardship Contracting

although the Forest Service created a monitoring team for the project, the 

team was formed after the NEPA process was completed and the contract 

awarded, minimizing the opportunity for public input. The HCPC member 

added that the project was too narrowly focused on the sale of timber and 

involved only limited restoration activities, such as culvert and road 

replacement.

Forest Service Response The Forest Service’s Buck project manager agreed that community 

involvement was lacking on the project, noting that public involvement was 

particularly limited during the project’s planning and design stages. He 

emphasized that future projects will likely involve more public input, 

especially during planning and design. 

With respect to concerns that the project’s focus was too narrow and 

involved limited restoration activities, the project manager noted that once 

the NEPA process was completed, the Forest Service was limited in the 

changes it could make to the project because significant alterations would 

have required going through the NEPA process again. Given the project’s 

initial focus as a timber sale, the amount of restoration activity that could 

be added after NEPA was limited. 

Hungry Hunter Ecosystem 

Restoration Pilot Project

The Hungry Hunter Ecosystem Restoration project is in Washington’s 

Okanogan and Wenatchee National Forests in the Forest Service’s Pacific 

Northwest Region. The project was designed to remove small-diameter 

trees, conduct prescribed burning, rehabilitate roads to improve habitat, 

and reduce erosion. The Forest Service project manager told us he 

expected the project to get under way in early 2004, following completion 

of the NEPA process.

Environmental Group Concerns A board member of the Methow Forest Watch, a local grass roots 

environmental group, expressed concerns about the Forest Service’s lack 

of commitment to and support for the project, which has delayed project 

implementation, as well as limited public involvement. Regarding the lack 

of commitment and support, she said the Forest Service has paid more 

attention to timber sale projects than to the Hungry Hunter project, citing a 

local timber sale as an example of a project that is already under way while 

the Hungry Hunter project is moving forward slowly. She stated that 

although she understands that forest fires have contributed to project 

delays, the Forest Service has not made the Hungry Hunter project a high 

priority. Concerning limited public involvement, the board member noted 
Appendix I

Forest Service’s Responses to 

Environmentalists’ Concerns about Projects 

Identified as Problematic

Page 48 GAO-04-652 Stewardship Contracting

that although the Forest Service initially incorporated public involvement 

on the project, this involvement was reduced after the Consolidated 

Appropriations Resolution of 2003 eliminated the requirement for local 

monitoring teams. She also noted that although the Forest Service initially 

proposed 1.3 miles of road as part of the project, the agency currently 

proposes constructing seven miles of new road, some of it in areas that are 

currently roadless.

Forest Service Response The Hungry Hunter project manager disagreed with the contention that 

there was a lack of commitment to the project. The manager noted that the 

comparison to the local timber sale does not demonstrate lack of 

commitment because the two projects did not start at the same time and, 

further, that the timber sale will be about 3 years late when it is finally 

completed. However, the project manager acknowledged the project’s 

delays and stated that he understands public frustration over these delays. 

He noted that in addition to severe fires that have directed Forest Service 

resources elsewhere, lack of clear agency guidance on how to implement 

the project has also contributed to delays. For example, he said the 

permissible use of retained receipts was initially unclear, but the new 

legislation and guidance clearly specifies what they can be used for. In 

addition, he noted that time-consuming soils analyses required as part of 

the project’s environmental assessment also caused delays.

The manager agreed that public involvement on the project has been 

reduced in recent months. He attributed this reduction to several factors. 

First, there was confusion over the requirements of the Consolidated 

Appropriations Resolution of 2003, including the extent of public 

involvement. Additionally, he was concerned about violating the Federal 

Advisory Committee Act (FACA) by working too closely with the project’s 

monitoring team; partly as a result, he reduced the team’s involvement. 

Finally, a potential conflict of interest arising from monitoring team 

members who were potential bidders on the project contract also 

contributed to the project manager’s decision to curtail monitoring team 

involvement. The manager emphasized, however, that once the 

environmental assessment is finalized and the project is under way, more 

direct and extensive public involvement will be resumed. 

Regarding the concern about high road densities in the Hungry Hunter 

project area, the project manager stated that no decision has yet been made 

regarding the number of miles of road in the project. He noted that four 

alternatives are outlined in the project’s environmental assessment, one of 

which would involve no new road construction. Once the public comment 
Appendix I

Forest Service’s Responses to 

Environmentalists’ Concerns about Projects 

Identified as Problematic

Page 49 GAO-04-652 Stewardship Contracting

period is completed, he said, a decision will be made on which alternative 

to select.

Sprinkle Restoration Pilot 

Project

The Sprinkle Restoration project, like the Buck project, is in Oregon’s 

Wallowa-Whitman National Forest in the Forest Service’s Pacific 

Northwest Region. The project’s specific objectives are to provide longterm forest health, reduce the severity of future insect infestations, restore 

the forest to historical conditions, and provide for wildlife habitat. A 

contract for the project was awarded in July 2003, and the contractor began 

working on the project in the spring of 2004.

Environmental Group Concerns A member of the Hell’s Canyon Preservation Council (the same member we 

spoke with regarding the Buck project) told us the group is mainly 

concerned about the lack of collaboration on the Sprinkle Restoration 

Project, but also has concerns about the project’s narrow focus on timber 

harvest activities to the detriment of restoration activities and the limited 

use of receipts retained. 

Regarding collaboration, the HCPC member told us that the local 

monitoring team was formed only after the project had been through the 

NEPA process and the contract had been signed and that community input 

on the project through NEPA is insufficient. However, he noted that the 

Forest Service is addressing some of the monitoring team’s concerns. For 

example, the team had noticed that a road that was to be decommissioned 

as part of the project required no action because the road area had 

adequately restored and regenerated itself. When the team pointed out that 

decommissioning the road would be unnecessary and would add sediment 

to a nearby creek, the Forest Service accepted the team’s suggestion and 

withdrew the plan to decommission the road. The HCPC member pointed 

out that if the Forest Service had involved the community up front, this 

oversight would not have occurred.

The HCPC member also told us that the project focused on timber harvest 

activities and did not address the issue of high road density, which 

jeopardizes wildlife security. More broadly, he told us that the project did 

not contain sufficient restoration activities and noted that additional 

activities (such as replacing culverts or decommissioning roads) could 

have been added to the project to fully use the expected $300,000 in 

retained receipts, which had not been used. 
Appendix I

Forest Service’s Responses to 

Environmentalists’ Concerns about Projects 

Identified as Problematic

Page 50 GAO-04-652 Stewardship Contracting

Forest Service Response The Sprinkle project manager told us he agrees that collaboration on the 

project has been lacking and that NEPA had been completed and the 

project designed before the monitoring team was formed. He stated that 

the Forest Service is trying to improve collaboration on planning various 

forest projects.

Concerning high road density, the project manager said that although road 

removals were planned as part of the project, road density remains high, 

contributing to reduced elk habitat. He noted, however, that the area is flat, 

making vehicle use difficult to manage. If the Forest Service closes a road, 

forest users are likely to simply take their vehicles off road to get where 

they want to go. Because it may be more ecologically sound to leave the 

roads in place and keep forest traffic on established roadways, there is 

some reluctance on the part of the Forest Service to close roads.

Finally, regarding retained receipts, the project manager informed us that 

the agency has consulted with the monitoring team on the use of the 

receipts. He said the Forest Service plans to use the funds on nearby 

stewardship projects as well as on the Sprinkle and adjacent watersheds. 

For example, the agency plans to use the funds to replace culverts within 

the Sprinkle area.

Meadow Face Pilot Project The Meadow Face project is located in Idaho’s Nez Perce National Forest in 

the Forest Service’s Northern Region. The project objectives are to return 

vegetation to its historical range; reduce fire risk, invasive plant species, 

and sediment; and improve stream channel conditions and recreational 

opportunities. No contract has been awarded on the project, and the 

project manager did not provide an estimate of its completion date.

Environmental Group Concerns Members of Friends of the Clearwater and the Idaho Conservation League, 

two local environmental groups, expressed concerns about insufficient 

public involvement in the project, insufficient restoration activities, 

overstatement of the results of project activities, and site-specific 

amendments made to the 1987 forest plan that allow environmental 

degradation.1

 Regarding public involvement, the Idaho Conservation 

League member said that the Stewards of the Nez Perce, an advisory group 

1

The Forest Service is required by law to develop a comprehensive, long-range management 

plan for each national forest. These plans, commonly called forest plans, must provide for 

multiple public uses in each forest, such as fishing, mining, and preserving wildlife.
Appendix I

Forest Service’s Responses to 

Environmentalists’ Concerns about Projects 

Identified as Problematic

Page 51 GAO-04-652 Stewardship Contracting

composed of representatives of the timber industry, the Idaho Department 

of Fish and Game, the Nez Perce tribe, environmentalists, and others, 

presented the Forest Service with a project proposal that was unanimously 

agreed upon by the group. However, the Forest Service ultimately ignored 

the group’s recommendation and came up with its own project, and the 

environmental group members do not believe the project will result in the 

completion of all restoration elements that were proposed.

The Friends of the Clearwater member also commented on one element of 

the service work—an attempt to reduce sedimentation into area 

waterways—involving the stabilization of a slide area resulting from past 

timber harvesting. The member argues that the Forest Service is double 

counting the sediment savings resulting from this activity—that is, 

representing the savings as the effect of mitigating the prior timber harvest 

as well as the effect of the current Meadow Face project.

Finally, the environmental group member expressed concern over three 

amendments that were made to the forest plan in order to allow project 

activities. He told us his group is concerned over forest plan amendments 

that will allow (1) higher levels of sedimentation in area waterways, (2) 

increased soil compaction in the area, and (3) logging activities within oldgrowth timber stands.

Forest Service Response Regarding the concern about ignoring the recommendations of the 

Stewards of the Nez Perce, local Forest Service officials noted that about 

90 percent of what was contained in the Stewards’ recommendations is 

included among the activities the Forest Service intends to undertake and 

that, in any case, the group was told repeatedly that its recommendations 

would not necessarily be implemented without further adjustment or 

review. Further, the Stewards’ recommendations were vague in certain 

respects, making it difficult to determine exactly what activities the group 

expected.

Project officials also noted that the stewardship project itself will 

encompass only a portion of the activities the Forest Service intends to 

undertake and that other contracting mechanisms—such as timber or 

service contracts—may also be implemented. Thus, the omission of certain 

activities from the stewardship project does not mean the restoration work 

will not be completed; rather, it simply means the Forest Service will 

complete the work using other means.
Appendix I

Forest Service’s Responses to 

Environmentalists’ Concerns about Projects 

Identified as Problematic

Page 52 GAO-04-652 Stewardship Contracting

With respect to the Meadow Creek slide area, the project manager said that 

the area is the result of ponds created by a homesteader, not the result of 

past timber harvesting. The area was included in a timber sale in order to 

remediate the slide area; the sediment savings resulting from this 

remediation were to offset the increased sediment that would result from 

logging activities. The timber sale is currently being implemented, but the 

slide area has not yet been treated, so it was included in the Meadow Face 

project. However, the official added that the Forest Service will not count 

the slide area remediation toward any “sediment savings” in the Meadow 

Face project.

Regarding the amendments to the 1987 forest plan, the project officials told 

us that the water quality amendment actually tightens the water quality 

requirements for two watersheds in the project area, meaning that less 

sediment will be permitted to flow into those streams. In the case of a third 

waterway, sediment restrictions were eased after forest staff determined 

that the streambed can handle more sediment than was initially believed 

when the forest plan was developed. 

The soil compaction amendment allows greater flexibility in conducting 

projects, according to project officials. The forest plan originally stated that 

upon completion of any forest activity, the soil in the area must be less than 

20 percent compacted, displaced, or puddled. However, many areas in the 

forest had undergone significant logging or other activities in the past and 

were already affected well beyond the 20 percent standard. Consequently, 

those areas were, in effect, off limits to any additional activities—whether 

timber harvesting or restoration activities—because remediating the soils 

to below the 20 percent standard would be difficult when they were 

substantially above the standard to begin with. The amendment to the 1987 

forest plan states generally that the level of compaction, displacement, or 

puddling after a project is completed must be lower than the level before 

the project—which in turn would allow activities, as long as the soils are 

left in better condition after the project than they were before it.

Finally, the officials told us that the old-growth logging amendment applies 

to about 710 acres of old-growth forest and allows treatment of the stands 

in order to maintain old-growth characteristics. The stands are becoming 

dense with small trees and underbrush that could serve as ladder fuels and 

possibly contribute to a stand-destroying fire. As a result of the 

amendment, the Forest Service can thin the stands, benefiting old-growth 

trees by reducing both ladder fuels and competition for water and 

nutrients.
Appendix I

Forest Service’s Responses to 

Environmentalists’ Concerns about Projects 

Identified as Problematic

Page 53 GAO-04-652 Stewardship Contracting

North Fork Big Game 

Habitat Restoration Pilot 

Project

The North Fork Big Game Habitat Restoration project (also known as the 

Middle Black project) is located in Idaho’s Clearwater National Forest in 

the Forest Service’s Northern Region. The project will involve thinning on 

about 640 acres, and the project manager expects it to be completed in 

2009.

Environmental Group Concerns A member of Friends of the Clearwater (the same member we spoke with 

regarding the Meadow Face project) told us that his organization is 

concerned that the project focuses more on increasing the elk population 

than on other environmental issues and will involve thinning trees and 

brush in roadless areas.

Forest Service Response The project manager told us that, while the Forest Service is seeking to 

restore the elk population, it is also engaged in restoration activities. He 

acknowledged that the project began as a study undertaken at the request 

of a local group called the Clearwater Elk Recovery Team (CERT), which 

was concerned about declining elk numbers. However, he emphasized that 

despite its origin, the project is being conducted as an ecosystem 

restoration effort that will restore the forest to a more typical historical 

condition and reduce the likelihood of fire. As evidence that the project has 

not paid undue attention to the elk recovery issue, the project manager told 

us that CERT members “complained vigorously” about the proposed plan 

for the project, even filing an appeal, because the project did not 

adequately address their concerns about elk habitat. The manager stated 

that although thinning will take place in roadless areas, no new roads will 

be built. Thinning will be conducted manually using chainsaws.

Granite Watershed 

Protection and 

Enhancement Pilot Project

The Granite Watershed Protection and Enhancement project is located in 

California’s Stanislaus National Forest in the Forest Service’s Pacific 

Southwest Region. The project is designed to achieve several objectives, 

including watershed and enhancement, spotted owl habitat improvement 

and protection, noxious weed control, and reforestation. The project is 

ongoing, and the project manager expects it to be completed in 2010.

Environmental Group Concerns Members of the Sierra Club and the Forest Conservation Council told us 

that their overall concern about the project is the Forest Service’s failure to 

account for all costs and benefits when designing the project. The members 

told us that while the project will open or reconstruct 63 miles of road to 

remove forest products, the Forest Service did not consider the project’s 
Appendix I

Forest Service’s Responses to 

Environmentalists’ Concerns about Projects 

Identified as Problematic

Page 54 GAO-04-652 Stewardship Contracting

impacts on other issues, such as sedimentation and big-game habitat, and 

the financial and nonfinancial costs and benefits of these potential impacts.

Forest Service Response The Granite project manager agreed that there are many costs and benefits 

associated with timber sales and other forest projects beyond those 

assessed for the Granite project, but he stated that quantifying all costs and 

benefits would be impossible. For example, he noted that timber harvests 

might deter people from using forest lands for recreational purposes. 

Although forest visitors may provide financial benefits such as gasoline 

purchases from nearby communities, visitors also leave trash behind, 

creating a nonmonetary cost by degrading the recreational experience of 

others and potentially creating a monetary cost for cleanup expenses. In 

addition, visitors’ vehicle use may also contribute to watershed damage by 

increasing sedimentation. Given that project effects are so mixed and 

involve so many elements that are impossible to quantify, according to the 

project manager, it would be impossible to account for all costs and 

benefits in a project analysis.

With respect to the specific impact on big-game habitat, the project 

manager noted that the project, as designed, would add less than one mile 

of road to existing roads in the forest. He added that if roads do, in fact, 

reduce habitat, the one additional mile of road will have little impact on 

this reduction. He said that the area is not known for big game; the only 

such game are deer and bears, and neither population has been thriving 

under existing conditions.
Page 55 GAO-04-652 Stewardship Contracting

Appendix II

Objectives, Scope, and Methodology ApendxiI

Based on the congressional request letters of July 2002 and March 2003, 

and subsequent discussions with your staffs, we agreed to determine (1) 

the status of each stewardship project and the land management goals they 

address; (2) the extent to which the agencies have contracting and financial 

controls in place that ensure accountability in managing stewardship 

projects; (3) the steps the agencies have taken to involve communities in 

designing, implementing, and evaluating stewardship projects; (4) each 

agency’s plans for future use of stewardship contracting; and (5) the Forest 

Service’s response to concerns raised about 6 specific stewardship 

projects.

Stewardship Project Status 

and Land Management 

Goals

To identify ongoing and completed stewardship pilot projects, we 

contacted officials at the Forest Service and BLM to obtain a list of such 

projects. The Forest Service provided a list of 81 pilot projects;1

 an official 

with BLM’s Forest and Woodland Management Group stated that no 

projects were ongoing. 

To determine the status of these stewardship projects and their land 

management goals, we conducted a Web-based survey of all ongoing and 

completed stewardship projects. The survey asked respondents to provide 

data on project activities, costs, time frames, size, and other information, as 

well as the land management goals addressed by each project. 

Because we surveyed all stewardship projects, no sampling error and 

confidence intervals are associated with our work. However, the practical 

difficulties of conducting any survey may introduce other types of errors, 

commonly referred to as nonsampling errors. For example, differences in 

how a particular question is interpreted, the sources of information 

available to respondents, or the types of people who do not respond can 

introduce unwanted variability into the survey results. We included steps in 

both the data collection and data analysis stages for the purpose of 

minimizing such nonsampling errors. We pretested the survey at three 

project sites and conducted a fourth pretest by telephone. In addition, we 

provided a draft version of the survey to Forest Service headquarters 

officials familiar with the stewardship contracting program in order to 

obtain their comments on the draft. We modified the survey as appropriate 

1

Although 84 pilot projects were authorized, several pilot projects had been terminated at 

the time of our review.
Appendix II

Objectives, Scope, and Methodology

Page 56 GAO-04-652 Stewardship Contracting

to reflect the questions and comments we received during the pretests and 

Forest Service headquarters review. 

Project managers at 4 of the 81 projects identified by the Forest Service 

told us that their projects had been terminated by the time of our survey or 

were no longer being conducted under stewardship authority, leaving 77 

projects. Of these 77 projects, 7 did not provide information in our survey. 

The managers for 3 projects—Butte South, Midstory Removal in RedCockaded Woodpecker Habitat, and Red River—told us that their projects 

were too preliminary to reasonably provide information. The manager of 

the Grassy Flats project told us that she was required to serve on 

firefighting duty and did not have time to complete our survey. The 

manager of the West Glacier project told us that because of demands on his 

time resulting from the 2003 wildfires in his state, he was faced with a 

substantial backlog of work and would not be able to complete our survey. 

Finally, the managers of the Grand Canyon and Yaak projects did not 

respond to our requests to provide data.

We attempted to corroborate survey responses in two ways. First, to the 

extent possible, we compared survey responses from the projects we 

visited with information (such as contracts or other documents) we 

collected during those visits. The survey data generally concurred with the 

site visit documentation we gathered. When we encountered substantial 

differences we could not reconcile, we used the more conservative figure. 

Such discrepancies occurred in four instances, two involving the estimated 

value of products removed, one involving the estimated volume of products 

removed, and one involving estimated contract costs. We also identified 

one source of data—the Forest Service’s Timber Sale Accounting (TSA) 

system—that contains data about the volume of timber removed as part of 

Forest Service timber sales. Because in our survey we asked about timber 

volumes removed during stewardship projects, we attempted to 

corroborate survey responses regarding timber volumes by comparing 

them to TSA data. The comparison was not meaningful, however, because 

of differences in the way the two sets of data (ours and TSA’s) were 

collected, and because the preliminary nature of many of the stewardship 

projects meant that, while they provided us with estimates of their timber 

harvest volumes, such data were not yet entered into TSA.

However, based on our comparison of survey responses to project 

documentation, we believe the data are sufficiently reliable to be used in 

providing descriptive information on project size, activities, land 

management goals, and the like. 
Appendix II

Objectives, Scope, and Methodology

Page 57 GAO-04-652 Stewardship Contracting

Contracting and Financial 

Controls

To assess the contracting and financial controls in place at stewardship 

projects, we conducted site visits to a nonprobability sample of 8 ongoing 

or completed project locations—about 10 percent of the 81 projects 

initially reported to us.2, 3

 We used numerous criteria to select project 

locations to visit. First, to respond to your interest in the Forest Service’s 

use of retained funds and its controls over contractor activities, we 

narrowed our scope to include only projects using receipt retention or 

designation by description authorities. From such projects we selected all 

of those that had been completed—a total of 4 projects. (One additional 

project had been completed but did not use either receipt retention or 

designation by description authority.)

To select the remaining 4 projects to visit, we first eliminated from our 

consideration any remaining projects in the Forest Service regions where 

the 4 completed projects were located, in order to obtain geographic 

spread in our nonprobability sample and obtain information from various 

Forest Service regions. We then focused on projects that were well under 

way, in order to ensure that sufficient contracting and financial activities 

had taken place for us to evaluate. Our application of these site selection 

criteria yielded the site visit locations shown in table 1.

2

Results from nonprobability samples cannot be used to make inferences about a 

population. This is because in a nonprobability sample, some elements of the population 

being studied have no chance or an unknown chance of being selected as part of the sample.

3

We also visited stewardship projects near Flagstaff, Arizona, and Fort Collins, Colorado. 

However, at these locations, we simply toured the project sites and did not apply our site 

visit methodology.
Appendix II

Objectives, Scope, and Methodology

Page 58 GAO-04-652 Stewardship Contracting

Table 1: Selection Criteria Met by Each Pilot Project at Which We Conducted Site Visits

Source: GAO.

At each site visit location, we reviewed the project’s contracting and 

financial files and interviewed Forest Service officials associated with the 

project, including project managers, timber sale contracting officers, 

procurement contracting officers, contracting officers’ representatives, 

supervisory accountants, and others, to determine whether appropriate 

controls were in place to provide accountability in managing the projects. 

We reviewed preaward and postaward contracting elements we identified 

as important for providing management accountability in awarding and 

administering stewardship contracts. Regarding preaward activities, we 

looked for evidence of solicitations and advertisements for the projects to 

provide public notice of work to be performed and to maximize the number 

of potential bidders on project contracts. We also looked for 

documentation of preestablished bid evaluation criteria to show that the 

Forest Service selected contractors fairly and equitably. In addition, given 

that stewardship projects may involve new ways of contracting to achieve 

land management objectives, we looked for evidence of meetings with 

prospective bidders to clarify project activities and Forest Service 

expectations. 

Regarding postaward controls, we reviewed contracts to determine 

whether they contained clear definitions of contract requirements as well 

as valuation, bond, oversight, and breach, default, and dispute resolution 

Criteria met

Project location Region

Using receipt 

retention 

authority

Using designation 

by description 

authority

Completed 

project

Geographically 

separate from 

completed projects 

Project 

activity under 

way

Clearwater 1 • • • •

Winiger Ridge 

Restoration

2 • • •

Warm Ridge/Glide 4 • • •

Antelope 6 • •

Baker City Watershed 

Rehabilitation

6 • •

Wayah Contract 

Logging

8 • • •

Burns Creek 8 • •

Fernow Experimental 

Forest

9 • • •
Appendix II

Objectives, Scope, and Methodology

Page 59 GAO-04-652 Stewardship Contracting

clauses to provide accountability in managing the projects. Clear 

definitions of contract requirements, accompanied by postaward 

conferences with contractors, ensure that contractors fully understand the 

Forest Service’s requirements and expectations. Appropriate valuation 

techniques, such as appraisals and government estimates, ensure that the 

government is fairly compensated for the timber or other products it is 

selling. Payment and performance bonds ensure that the government 

receives payment for timber harvested and that government funds are not 

required to remediate damage caused by contractor activities. Oversight 

activities assure the government that contractor activities are being 

conducted appropriately and according to schedule. Finally, breach, 

default, and dispute resolution clauses allow the Forest Service to address 

problems by issuing default notices or stop work orders to prohibit further 

activity on a project until the problems are resolved.

In addition, at 6 of the 8 sites we visited, we met with the contractor 

performing the stewardship activities, in order to obtain the contractor’s 

perspective on the project. Finally, we spoke with officials of the Forest 

Service’s Forest and Rangeland Management Group, BLM’s Forest and 

Woodland Management Group, and various agency field staff regarding the 

contracting and financial guidance provided to staff implementing 

stewardship projects.

Based on our reviews of agency files, discussions with agency staff, and 

interviews of contractors outside the agency, we believe the data are 

sufficiently reliable to be used in reporting on the contracting and financial 

mechanisms employed by the Forest Service in implementing stewardship 

projects.

Community Involvement To determine the measures taken by the agencies to involve communities 

in designing, implementing, and evaluating stewardship projects, we 

reviewed project contracting files and interviewed agency officials at each 

of our 8 site visit locations. At 5 of the 8 locations, we also spoke with a 

member of the local monitoring team to obtain additional information on 

the monitoring team’s role in the project. The remaining 3 locations did not 

have monitoring teams.

In addition to these 8 projects, we conducted structured telephone 

interviews with officials at a nonprobability sample of an additional 25 

randomly selected projects. In order to select these projects, we first 

eliminated from consideration those projects that (1) indicated through our 
Appendix II

Objectives, Scope, and Methodology

Page 60 GAO-04-652 Stewardship Contracting

survey they were no longer viable stewardship projects, (2) were included 

among our 8 site visits, and (3) were among the 6 included in our 

assessment of projects about which concerns had been raised. Of the 

remaining 63 projects, 40 had completed NEPA, according to Forest 

Service data, and 23 had not. From these 63 projects we randomly selected 

a total of 25 projects to contact—15 that had completed NEPA and 10 that 

had not. Our nonprobability sample of 25 projects was similar to our 

universe of 63 projects in the percentage of projects that had and had not 

completed NEPA. We then contacted officials at these 25 projects to ask a 

set of questions regarding community involvement in the projects. Again, 

we included steps to minimize nonsampling errors. In lieu of pretesting the 

questions, we used the results of our site visits to ensure that the questions 

we asked were understandable, balanced, and appropriate. 

We also spoke with staff from the Pinchot Institute for Conservation (the 

Forest Service contractor overseeing multiparty monitoring and 

evaluation) regarding community involvement, and attended the spring 

2003 meeting of the Pinchot Institute’s national stewardship monitoring 

team.

Because we gathered complementary data from multiple sources, including 

Forest Service project managers, Pinchot Institute staff, and local and 

national monitoring team members, we believe the data we gathered are 

sufficiently reliable to be used in reporting on the measures taken by the 

agencies to involve communities in stewardship projects.

Future Agency Activities To obtain information on future agency stewardship activities, we reviewed 

both the Forest Service’s and BLM’s January 2004 guidance on stewardship 

contracting. We also obtained from Forest Service and BLM headquarters 

officials the number of projects they currently had under way or had 

planned in addition to the 77 pilot projects undertaken by the Forest 

Service. Finally, we spoke with headquarters officials at both agencies to 

obtain their views on future use of stewardship contracting authority and 

their plans for future monitoring and assessment activities.

Projects of Concern To determine the Forest Service’s response to specific concerns raised 

about 6 ongoing stewardship projects by environmental group 

representatives, we first obtained the concerns of environmental group 

representatives for each of the 6 projects. To do so, we telephoned the 

environmental contacts listed by your staff to obtain information on their 
Appendix II

Objectives, Scope, and Methodology

Page 61 GAO-04-652 Stewardship Contracting

concerns. We also requested documentation such as appeal documents 

filed, correspondence with Forest Service officials, or other documentation 

that could provide information on concerns regarding the projects. 

Subsequently, we telephoned the Forest Service managers for each of these 

6 projects to obtain their responses to the concerns that had been raised. 

Based on our discussions with individuals concerned about specific 

stewardship projects and Forest Service staff associated with the projects, 

as well as our review of documentation regarding the projects, we believe 

the data are sufficiently reliable to be used in reporting on concerns about 

specific stewardship projects and the Forest Service’s response to those 

concerns. 

We conducted our work between April 2003 and April 2004 in accordance 

with generally accepted government auditing standards.
Page 62 GAO-04-652 Stewardship Contracting

Appendix III

Pilot Project Names, Locations, Acres Treated, 

and End Dates ApendxiI

Table 2 provides pilot project information as of September 30, 2003, as 

reported by project officials.

Table 2: Pilot Project Names, Locations, Acres Treated, and End Dates

Project name National forest

Project 

acresa

Project 

end dateb

Region 1: Northern Region

Bitterroot Burned Area Restoration Bitterroot 7,284 9/30/2005

Butte South Beaverhead-Deerlodge c c

Clancy-Unionville Helena — —

Clearwater Lolo 1,280 11/30/2004

Condon Administrative Site Fuels Reduction Flathead 17 9/30/2003

Dry Fork Lewis and Clark 300 9/30/2005

Dry Wolf Lewis and Clark 149 9/30/2004

Frenchtown Face Lolo — —

Game Range Lolo 2,221 12/31/2007

Iron Honey Idaho Panhandle 7,200 -

Judith Vegetation and Range Restoration Lewis and Clark 218 9/30/2006

Knox-Brooks Lolo 802 11/30/2007

Main Boulder Gallatin 2,505 4/30/2010

Meadow Face Nez Perce 59 —

North Elkhorns Helena — —

North Fork Big Game Habitat Restoration (also referred to as 

Middle Black Ecosystem Restoration) 

Clearwater 11,000 9/30/2009

Paint Emery Flathead 231 11/30/2004

Priest-Pend Oreille Idaho Panhandle 2,017 2/5/2009

Red River Nez Perce c c

Sheafman Fuels Reduction Bitterroot 104 10/31/2004

Treasure Interface Kootenai 765 9/30/2004

Westface Forest Management Beaverhead-Deerlodge 407 10/31/2007

West Glacier Flathead d d

Yaak Kootenai e e

Region 2: Rocky Mountain Region

Beaver Meadows Restoration San Juan 902 9/30/2008

Ryan Park/Ten Mile Medicine Bow-Routt National Forests and 

Thunder Basin National Grasslands

879 12/31/2008

Seven Mile Arapaho-Roosevelt 1,375 6/30/2005

Southwest Ecosystem San Juan 38 9/30/2003
Appendix III

Pilot Project Names, Locations, Acres 

Treated, and End Dates

Page 63 GAO-04-652 Stewardship Contracting

Upper Blue White River 1,834 12/1/2013

Upper South Platte Watershed Pike-San Isabel — —

Winiger Ridge Restoration Arapaho-Roosevelt 1,066 10/5/2005

Region 3: Southwestern Region

Cottonwood/Sundown Apache-Sitgreaves 210 9/30/2002

Grand Canyon Coconino e e

Montlure/Benne Thin and Fuels Reduction Apache-Sitgreaves 358 12/31/2004

Ranch/Iris Winter Range Restoration Apache-Sitgreaves 2,000 12/31/2004

Zuni-Four Corners Cibola 33 9/24/2003

Region 4: Intermountain Region

Atlanta South Fuels Reduction Boise 582 12/31/2005

Duck Creek Village Dixie 12,000 12/31/2008

Warm Ridge/Glide Boise 3,500 9/30/2007

Monroe Mountain Ecosystem Restoration Fishlake 4,971 11/30/2009

North Kennedy-Cottonwood Boise 3,248 12/31/2009

Recap Density Management Dixie 155 12/31/2003

Small Wood Utilization Boise 20,000 9/30/2008

Region 5: Pacific Southwest Region

Granite Watershed Protection and Enhancementf Stanislaus 7,075 12/1/2010

Grassy Flats Shasta-Trinity g g

Maidu Plumas 1,300 11/30/2013

Pilot Creek Six Rivers 164 11/15/2007

Region 6: Pacific Northwest Region

Antelope Fremont-Winema 1,644 9/23/2002

Baker City Watershed Rehabilitation Wallowa-Whitman 628 5/15/2001

Buck Wallowa-Whitman 880 3/31/2004

Foggy/Eden Siskiyou 4,614 9/30/2010

Hungry Hunter Ecosystem Restoration Okanogan-Wenatchee 17,906 2011

Littlehorn Wild Sheep Habitat Restoration Colville 350 11/30/2004

McKenzie Willamette 250 12/31/2006

Metolius Basin Forest Management Deschutes 12,600 12/31/2011

Oh Deer Okanogan-Wenatchee 215 3/31/2005

Siuslaw Basin Rehabilitation Siuslaw 2,960 9/30/2008

Sprinkle Restoration Wallowa-Whitman 2,642 10/31/2007

Upper Glade Rogue River 396 12/31/2006

(Continued From Previous Page)

Project name National forest

Project 

acresa

Project 

end dateb
Appendix III

Pilot Project Names, Locations, Acres 

Treated, and End Dates

Page 64 GAO-04-652 Stewardship Contracting

Source: GAO.

Note: A dash indicates that project officials did not respond to this question in our survey.

a

Project acres include acres treated at the time of our survey and acres expected to be treated in the 

future.

b

Project end date reflects the date on which the pilot project’s final contract was, or is expected to be, 

closed.

c

Project officials told us these projects were too preliminary to provide meaningful survey responses.

d

The West Glacier project manager told us that because of his heavy workload resulting from 2003 

wildfires in his forest, he did not have time to complete our survey.

e

Grand Canyon and Yaak project officials did not respond to our survey.

f

The Granite Watershed Protection and Enhancement project was authorized by the Granite 

Watershed Enhancement and Protection Act of 1998 (Pub. L. No. 105-281, 112 Stat. 2695) rather than 

by the stewardship contracting legislation. A project official told us, however, that the project is being 

conducted under both authorities—the stewardship contracting legislation and the Granite Watershed 

Enhancement and Protection Act of 1998.

g

The Grassy Flats project manager told us she did not complete our survey because she was serving 

on firefighting duty in another location.

Region 8: Southern Region

Burns Creek George Washington-Jefferson 32 3/15/2002

Comp 113 Red-Cockaded Woodpecker Habitat

Improvement

Chattahoochee-Oconee 7,000 9/30/2010

Elk and Bison Prairie Habitat Restoration Land between the Lakes National Recreation 

Area

50 9/30/2005

First Loblolly Pine Thinning Francis Marion-Sumter 10,734 10/20/2006

Fugate Branch Daniel Boone 1,376 —

Longleaf Ecosystem Restoration and Red-Cockaded

Woodpecker Habitat Improvement

National Forests in Florida 2,389 —

Longleaf Restoration National Forests in Alabama 4,222 9/30/2010

Midstory Removal in Red-Cockaded Woodpecker Habitat National Forests in Mississippi c c

Wayah Contract Logging (also referred to as Morgan

Cut)

National Forests in North Carolina 14 7/1/2003

Sand Mountain Contract Logging Services National Forests in North Carolina 55 4/30/2004

Southern Pine Beetle Suppression Francis Marion-Sumter 58 11/30/2003

Wolf Creek Cherokee 250 —

Region 9: Eastern Region

Fernow Experimental Forest Monongahela 792 9/30/2005

Forest Discovery Trail White Mountain 10 11/2001

Kirtland's Warbler Recovery Huron-Manistee 1,749 7/15/2007

North Montowibo Vegetation Management Ottawa 100 6/1/2008

Snowmobile Trail 13 Reroute Ottawa 4 6/1/2004

White River Riparian Buffer Green Mountain-Finger Lakes 16 2014

(Continued From Previous Page)

Project name National forest

Project 

acresa

Project 

end dateb
Page 65 GAO-04-652 Stewardship Contracting

Appendix IV

Comments from the Department of 

Agriculture ApendxiIV
Page 66 GAO-04-652 Stewardship Contracting

Appendix V

GAO Contacts and Staff Acknowledgments ApendxiV

GAO Contacts Barry T. Hill, (202) 512-3841

David P. Bixler, (202) 512-7201

Staff 

Acknowledgments

In addition to those named above, Paul Caban, Nancy Crothers, Timothy 

DiNapoli, James Espinoza, Steve Gaty, Kevin Jackson, Richard Johnson, 

Diane Lund, Mary Mohiyuddin, Judy Pagano, and Alana Stanfield made key 

contributions to this report.

(360332)
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