Report to the Chairman, Committee on 

Energy and Natural Resources, 

U.S. Senate 

United States Government Accountability Office

GAO 

FEDERAL LAND 

MANAGEMENT 

Additional 

Documentation of 

Agency Experiences 

with Good Neighbor 

Authority Could 

Enhance Its Future 

Use 

February 2009 

GAO-09-277 
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

February 2009

FEDERAL LAND MANAGEMENT 

Additional Documentation of Agency Experiences

with Good Neighbor Authority Could Enhance Its

Highlights of GAO-09-277, a report to the Future Use 

Chairman, Committee on Energy and 

Natural Resources, U.S. Senate 

In 2000, Congress authorized the 

U.S. Department of Agriculture’s 

Forest Service to allow the 

Colorado State Forest Service to 

conduct certain activities, such as 

reducing hazardous vegetation, on 

U.S. Forest Service land when 

performing similar activities on 

adjacent state or private land. The 

Department of the Interior’s 

Bureau of Land Management 

(BLM) received similar “Good 

Neighbor” authority in 2004, as did 

the U.S. Forest Service in Utah. 

Congress has also considered the 

authority’s expansion to other 

states. GAO was asked to 

determine (1) the activities 

conducted under the authority; 

(2) the federal and state guidance, 

procedures, and controls used to 

conduct Good Neighbor projects; 

and (3) successes, challenges, and 

lessons learned resulting from the 

authority’s use. To do so, GAO 

reviewed Good Neighbor project 

documentation and interviewed 

federal and state officials. 

What GAO Recommends

GAO recommends that the 

Secretaries of Agriculture and the 

Interior (1) require that the U.S. 

Forest Service in Utah, BLM in 

Colorado, and any agencies that 

receive the authority in other 

states, develop written procedures 

for Good Neighbor timber sales 

before conducting any future sales 

and (2) direct the agencies to better 

document their experiences using 

the authority. The U.S. Forest 

Service, Interior, and the Colorado 

and Utah forest agencies generally 

agreed with the report’s findings 

and recommendations. 

Fifty-three projects were conducted under Good Neighbor authority through 

fiscal year 2008, including 38 in Colorado and 15 in Utah, with most of the 

projects (44 of 53) conducted on U.S. Forest Service land. These projects 

included hazardous fuel reduction on about 2,700 acres of national forest and 

about 100 acres of BLM land, mostly in Colorado, and the repair of firedamaged trails and watershed protection and restoration in Utah. Together, 

the two agencies spent about $1.4 million on these projects, split almost 

evenly between the two states. Although most projects involved contracting 

for services such as fuel reduction, some projects involved timber sales in 

which contractors purchased timber resulting from their fuel reduction 

activities. These timber sales occurred only in Colorado and totaled about 

$26,000. 

State procedures are used in conducting Good Neighbor projects that involve 

service contracts, while projects that include timber sales incorporate both 

state and federal requirements. Both Colorado and Utah have contracting 

requirements that generally address three fundamental principles of 

government contracting—transparency, competition, and oversight. For 

example, both states solicit competition among bidders and generally require 

service contracts to be awarded to the lowest-priced bidder meeting the 

contract criteria. State requirements were generally comparable to federal 

procurement requirements. When Good Neighbor projects involve timber 

sales, state procedures incorporate certain requirements that help the U.S. 

Forest Service account for state removal of federal timber. The U.S. Forest 

Service and Colorado are currently supplementing their joint Good Neighbor 

procedures to ensure that additional accountability provisions are included in 

future timber sale contracts. Neither BLM in Colorado nor the U.S. Forest 

Service in Utah has developed written procedures for conducting Good 

Neighbor timber sales, primarily because they have not sold timber under the 

authority. Such procedures could help ensure accountability for federal 

timber if future projects include such sales. 

Federal and state officials who have used Good Neighbor authority cited 

project efficiencies and enhanced federal-state cooperation as its key benefits. 

For example, the agencies cited their ability to improve the effectiveness of 

fuel reduction treatments in areas that include federal, state, and private 

ownership. Federal and state agencies have also encountered challenges such 

as a lack of understanding of the authority and complicated processes for 

approving Good Neighbor agreements. Agency officials and others also noted 

several factors to consider when conducting future Good Neighbor projects, 

whether in Colorado, Utah, or other states that may be granted the 

authority—including the type of projects to be conducted and the type of land 

to be treated. While the agencies are not required to document their 

experiences in using the authority, officials contemplating future use of the 

authority could benefit from such documentation—including information on 

successes, challenges, and lessons learned to date. 

To view the full product, including the scope 

and methodology, click on GAO-09-277. 

For more information, contact Robin Nazzaro 

at (202) 512-3841 or nazzaror@gao.gov. 
Contents 

Letter 1

Results in Brief 3

Background 6 

Fifty-three Good Neighbor Projects Have Been Conducted in 

Colorado and Utah for Fuel Reduction and Other Purposes 11 

Good Neighbor Projects Are Generally Governed by State 

Procedures, but Projects Involving Timber Sales Also 

Incorporate Certain Federal Requirements 19 

Experiences with Good Neighbor Authority to Date Could, If Better 

Documented, Provide Insight for Potential Expansion of Its Use 27 

Conclusions 37 

Recommendations for Executive Action 38 

Agency Comments and Our Evaluation 38 

Appendix I Objectives, Scope, and Methodology 40 

Appendix II Comments from the U.S. Department of Agriculture’s 

Forest Service 43 

Appendix III Comments from the Department of the Interior 45 

Appendix IV Comments from the Colorado State Forest Service 46 

Appendix V Comments from the Utah Division of Forestry, Fire 

and State Lands 47 

Appendix VI GAO Contact and Staff Acknowledgments 48 

Figures 

Figure 1: Good Neighbor Projects in Colorado, by National Forest 

and BLM Area 12 

Page i GAO-09-277 Good Neighbor Authority 
Figure 2: Completed Fuel Reduction Project in Pike National 

Forest with Slash Piled for Burning 14 

Figure 3: Good Neighbor Projects in Utah, by National Forest 17 

Figure 4: Barrier Rocks Placed along Dixie National Forest 

Roadway to Prevent Off-road Vehicle Use 18 

Figure 5: Fuel Reduction Project Site in National Forest Area 

Bordering Private Subdivision 28 

Abbreviations 

BLM Bureau of Land Management 

CSFS Colorado State Forest Service 

CSU Colorado State University 

FAR Federal Acquisition Regulation 

NEPA National Environmental Policy Act 

UDFFSL Utah Division of Forestry, Fire and State Lands 

This is a work of the U.S. government and is not subject to copyright protection in the 

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without further permission from GAO. However, because this work may contain 

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necessary if you wish to reproduce this material separately. 

Page ii GAO-09-277 Good Neighbor Authority 
United States Government Accountability Office

Washington, DC 20548 

 

February 25, 2009 

The Honorable Jeff Bingaman 

Chairman 

Committee on Energy and Natural Resources 

United States Senate 

Dear Mr. Chairman: 

The state of our nation’s forests is of increasing concern, as many forests, 

whether in federal, state, or other ownership, have become densely 

stocked with trees and damaged by insects––two conditions that can 

increase the risk of severe wildland fires. In some cases, forests at high 

risk of fire span federal, state, and private land, making it difficult for a 

single entity to gain access to and address all areas needing protective or 

restorative treatment, such as reducing vegetation that can fuel wildland 

fires. Treating certain areas while leaving adjacent areas untreated may 

undermine the effectiveness of overall efforts––a problem that is 

particularly significant in Colorado and other western states undergoing 

increasing human development in or near wildlands, because these areas 

of wildland-urban interface often involve multiple landowners. In 1998, the 

U.S. Department of Agriculture’s Forest Service and the Colorado State 

Forest Service (CSFS) began investigating ways to address this issue. As a 

result, in 2000 Congress authorized the U.S. Forest Service to undertake a 

pilot program referred to as “Good Neighbor.” This legislation authorizes 

the U.S. Forest Service to permit CSFS to conduct certain watershed 

restoration activities––such as reducing hazardous fuel to prevent 

wildland fires, addressing insect outbreaks, and improving drainage to 

prevent sediment from eroding into forest watersheds––on U.S. Forest 

Service land when conducting similar activities on adjacent state or 

private land.1

 Under the act, the state may in some circumstances act as an 

agent of the federal government to conduct these projects. Although the 

projects are conducted by the state, projects on federal land remain 

subject to the provisions of the National Environmental Policy Act 

The state of our nation’s forests is of increasing concern, as many forests, 

whether in federal, state, or other ownership, have become densely 

stocked with trees and damaged by insects––two conditions that can 

increase the risk of severe wildland fires. In some cases, forests at high 

risk of fire span federal, state, and private land, making it difficult for a 

single entity to gain access to and address all areas needing protective or 

restorative treatment, such as reducing vegetation that can fuel wildland 

fires. Treating certain areas while leaving adjacent areas untreated may 

undermine the effectiveness of overall efforts––a problem that is 

particularly significant in Colorado and other western states undergoing 

increasing human development in or near wildlands, because these areas 

of wildland-urban interface often involve multiple landowners. In 1998, the 

U.S. Department of Agriculture’s Forest Service and the Colorado State 

Forest Service (CSFS) began investigating ways to address this issue. As a 

result, in 2000 Congress authorized the U.S. Forest Service to undertake a 

pilot program referred to as “Good Neighbor.” This legislation authorizes 

the U.S. Forest Service to permit CSFS to conduct certain watershed 

restoration activities––such as reducing hazardous fuel to prevent 

wildland fires, addressing insect outbreaks, and improving drainage to 

prevent sediment from eroding into forest watersheds––on U.S. Forest 

Service land when conducting similar activities on adjacent state or 

private land.

 

1

 Under the act, the state may in some circumstances act as an 

agent of the federal government to conduct these projects. Although the 

projects are conducted by the state, projects on federal land remain 

subject to the provisions of the National Environmental Policy Act 

1

Pub. L. No. 106-291, § 331 (2000). 

Page 1 GAO-09-277 Good Neighbor Authority 
 

(NEPA),2 which requires federal agencies to consider any significant 

environmental impacts that may result from their actions. 

Initially, Good Neighbor authority was slated to expire at the end of fiscal 

year 2004, but Congress passed legislation that year extending the 

authority until the end of fiscal year 2009.3

 The 2004 legislation also 

expanded Good Neighbor authority to include lands in Colorado managed 

by the Department of the Interior’s Bureau of Land Management (BLM); 

this authority also expires in 2009. The same legislation also established 

similar Good Neighbor authority concerning U.S. Forest Service land in 

Utah, but did not require the state to conduct similar work on adjacent 

state or private land; U.S. Forest Service authority in Utah expired at the 

end of fiscal year 2008. 

As Good Neighbor authority nears its expiration in Colorado and awaits 

reauthorization in Utah, Congress has considered potential expansion of 

the authority to other states. Legislation was introduced in the 110th 

Congress that would expand this authority to include U.S. Forest Service 

land in Wyoming,4

 or to include all U.S. Forest Service and BLM land in the 

western United States.5

 In this context, you asked us to determine (1) the 

activities conducted under Good Neighbor authority, including the 

number, type, and scope of projects undertaken; (2) the federal and state 

guidance, procedures, and controls being used to conduct Good Neighbor 

projects, including contracting requirements and timber sale procedures; 

and (3) the successes, challenges, or lessons learned, if any, that have 

resulted from the use of Good Neighbor authority. 

To determine the activities conducted under Good Neighbor authority in 

Colorado and Utah, we reviewed and analyzed documentation from the 

U.S. Forest Service; BLM; CSFS; and the Utah Division of Forestry, Fire 

and State Lands (UDFFSL). We also visited several completed or ongoing 

Good Neighbor project sites in both Colorado and Utah and interviewed 

 

2

For major actions that may significantly affect the quality of the human environment, the 

act requires all federal agencies, including the U.S. Forest Service and BLM, to analyze the 

potential environmental effects of the proposed action. See 42 U.S.C. § 4332(2)(C). 

3

Pub. L. No. 108-447, § 336 (2004). 

4

S. 2468 (2007). 

5

S. 3302 (2008). The bill would have covered any state “that contains National Forest 

System land or Bureau of Land Management land located west of the 100th meridian.” 

Page 2 GAO-09-277 Good Neighbor Authority 
 

federal and state officials to obtain an understanding of the type and scope 

of work being conducted under the authority. To determine the federal 

and state guidance, procedures, and controls used to conduct projects 

under Good Neighbor authority, we reviewed project operating 

procedures, federal and state procurement requirements, and federal and 

state timber sale requirements, comparing the requirements in several 

areas to identify similarities and differences. Finally, to determine the 

successes, challenges, and lessons learned resulting from the use of Good 

Neighbor authority, we interviewed federal and state officials involved 

with the authority’s use in Colorado and Utah and discussed the potential 

uses of Good Neighbor authority with state officials in Idaho, Oregon, and 

Wyoming. We also spoke with other interested parties, including 

environmental groups and industry representatives based in Colorado, 

Utah, other western states, and Washington, D.C. Appendix I contains 

more detailed information on the objectives, scope, and methodology of 

our review. We conducted this performance audit from June 2008 through 

February 2009 in accordance with generally accepted government auditing 

standards. Those standards require that we plan and perform the audit to 

obtain sufficient, appropriate evidence to provide a reasonable basis for 

our findings and conclusions based on our audit objectives. We believe 

that the evidence obtained provides a reasonable basis for our findings 

and conclusions based on our audit objectives. 

Fifty-three projects have been conducted under Good Neighbor authority 

as of the end of fiscal year 2008, including 38 in Colorado and 15 in Utah, 

with most of the projects (44 of 53) conducted on U.S. Forest Service land. 

These projects included fuel reduction on about 2,700 acres of national 

forest and about 100 acres of BLM land, mostly in the Colorado wildlandurban interface, and the repair of fire-damaged trails and watershed 

protection and restoration in Utah. Together, the two agencies spent about 

$1.4 million on these projects, split almost evenly between the two states. 

Although most projects involved paying contractors for services such as 

fuel reduction (i.e., service contracts), some projects involved timber sales 

in which, for example, contractors purchased timber resulting from their 

fuel reduction activities. Such timber sales amounted to about $26,000. 

The specific purpose for using Good Neighbor authority to conduct 

projects varied. For example, under Good Neighbor authority, Colorado 

contracted with a single vendor to carry out fuel reduction activities 

across multiple tracts of land with fragmented federal, state, and private 

land ownership, to avoid leaving pockets of untreated forest in the project 

area. 

Results in Brief 

Page 3 GAO-09-277 Good Neighbor Authority 
 

Both federal and state guidance, procedures, and controls are used in 

conducting Good Neighbor projects; state procedures are used in 

conducting projects that involve service contracts, while projects that 

include timber sales incorporate both federal and state requirements. For 

all Good Neighbor projects, the U.S. Forest Service and BLM are 

responsible for ensuring compliance with NEPA. For those projects 

involving service contracts, a master agreement with each state allows 

Colorado and Utah to use state procedures to enter into contracts with 

vendors that provide services such as fuel reduction. We examined both 

states’ contracting requirements concerning three fundamental principles 

of government contracting—transparency, competition, and oversight––

and found that state requirements generally address each of these areas. 

For example, we found that both states solicit competition among bidders, 

give potential contractors reasonable amounts of time to prepare bids, and 

generally require service contracts to be awarded to the lowest-priced 

bidder meeting the contract criteria. We also found state requirements to 

be generally comparable to federal procurement requirements in specific 

areas that we examined. When Good Neighbor projects involve timber 

sales, state procedures incorporate certain requirements that help the U.S. 

Forest Service account for state removal of federal timber. For example, 

Good Neighbor project procedures developed jointly by the U.S. Forest 

Service and CSFS direct state foresters to work with U.S. Forest Service 

officials to appraise the value of timber on the project site and determine 

the minimum bid price. However, we found that the provisions in standard 

U.S. Forest Service timber sale contracts are typically more extensive than 

those in timber sales administered by CSFS under Good Neighbor 

authority. For example, initial Good Neighbor timber sale contracts 

administered by CSFS did not include certain elements—such as 

provisions requiring the contractor to address aspects of road 

maintenance, or information about whether there were threatened and 

endangered species in the project area—that are part of U.S. Forest 

Service contracts. The U.S. Forest Service and CSFS developed more 

detailed Good Neighbor procedures to ensure that these types of 

provisions are included in future Good Neighbor timber sale contracts 

administered by Colorado, and are supplementing these procedures to 

strengthen timber accountability. We did not compare Colorado’s timber 

sale requirements with those of BLM, or Utah’s requirements with those of 

the U.S. Forest Service, because neither BLM in Colorado nor the U.S. 

Forest Service in Utah has conducted timber sales under Good Neighbor 

authority to date. Neither BLM in Colorado nor the U.S. Forest Service in 

Utah has developed written procedures for conducting Good Neighbor 

projects involving timber sales; such procedures could help ensure 

Page 4 GAO-09-277 Good Neighbor Authority 
 

accountability for federal timber if future Good Neighbor projects on the 

part of these agencies involve the sale of such timber. 

Experiences with Good Neighbor authority in Colorado and Utah may 

provide insights for the authority’s potential expansion in those states and 

others, although the agencies can enhance the usefulness of these insights 

by systematically documenting their experiences in using the authority. 

Federal and state officials who have used Good Neighbor authority cited 

project efficiencies and enhanced federal-state cooperation as its key 

benefits. For example, the agencies cited their ability to begin projects 

more quickly; work on federal lands that are otherwise difficult to access 

because they are surrounded by private property; and improve the 

effectiveness of fuel reduction treatments in areas that include federal, 

state, and private ownership. On the other hand, federal and state agencies 

have encountered some challenges in using the authority, such as a lack of 

understanding of the authority, which has complicated partnerships 

between federal and state officials. In addition, some U.S. Forest Service 

officials in Colorado considered state timber sale procedures to be 

insufficient to protect federal interests and have imposed additional 

requirements on the state before agreeing to Good Neighbor projects. 

Conversely, some state officials have found the overlay of federal 

requirements burdensome, making them less likely to participate in Good 

Neighbor projects. Federal, state, and other stakeholders identified several 

factors to consider when conducting future Good Neighbor projects. For 

example, to ensure the support of the public and environmental groups, 

some suggested that projects be undertaken only in the wildland-urban 

interface, where the potential public benefit is the greatest. Moreover, 

several stakeholders noted that, while it is important to understand the 

experiences using Good Neighbor authority in Colorado and Utah when 

considering its expansion to other states, it is likewise important to 

account for differences among states as well. Stakeholders told us that 

differences in the structure, staffing levels, and workload of other state 

forest services, and the characteristics of federal lands in various states—

particularly the value of timber on these lands—would all affect the 

authority’s chances for success in other states and, thus, are important 

factors to consider when evaluating its potential expansion. Consequently, 

agency officials contemplating future use of the authority—whether in 

Colorado, Utah, or other states—would benefit from documentation of 

agency experiences in using the authority to date. Such documentation 

could include, for example, an analysis of cost savings or other efficiencies 

that have been achieved through its use, and a discussion of the types of 

projects in which Good Neighbor authority has been most successful. 

Without such information, agency officials will need to independently 

Page 5 GAO-09-277 Good Neighbor Authority 
 

assess which projects would best be conducted using the authority, 

including the extent to which individual projects might reduce costs or 

lead to other efficiencies—an inefficient approach that could reduce the 

potential value of Good Neighbor authority. 

To enhance the U.S. Forest Service and BLM’s use of Good Neighbor 

authority, we are recommending that they (1) develop written procedures 

for Good Neighbor timber sales before conducting these sales in areas 

where such procedures do not already exist and (2) document how prior 

experiences with Good Neighbor projects offer lessons for the future, and 

make this information available to current and prospective users of the 

authority. In commenting on a draft of this report, the U.S. Forest Service, 

the Department of the Interior, CSFS, and UDFFSL generally agreed with 

its findings and recommendations. However, we are concerned that the 

actions the U.S. Forest Service intends to take in addressing our 

recommendation to better document agency experiences with Good 

Neighbor authority will not meet the intent of that recommendation, and 

we have noted this concern in our response to the agency’s letter. 

Comments from the U.S. Forest Service (along with our response to those 

comments), the Department of the Interior, CSFS, and UDFFSL are 

reprinted in appendixes II, III, IV, and V, respectively. 

Although its effect on communities can be devastating, wildland fire is a 

natural and necessary process that provides many benefits to ecosystems, 

such as maintaining habitat diversity, recycling soil nutrients, limiting the 

spread of insects and disease, and promoting new growth by causing the 

seeds of fire-dependent species to germinate. Wildland fire also 

periodically removes brush, small trees, and other vegetation that can 

otherwise accumulate and increase the size, intensity, and duration of 

subsequent fires. Wildland fire occurs in various combinations of 

frequency and severity, from low-severity events that return every few 

decades to high-severity fires that occur once every 200 years or more. 

Over the past century, however, various management practices—including 

fire suppression, grazing, and timber harvest—have reduced the normal 

frequency of fires in many forest and rangeland ecosystems and 

contributed to abnormally dense, continuous accumulations of vegetation, 

which can fuel uncharacteristically large or severe wildland fires. The 

impacts of these fires have intensified as more and more communities 

develop in areas that are adjacent to fire-prone lands—the wildland-urban 

interface. Federal researchers have estimated that unnaturally dense fuel 

accumulations on 90 million to 200 million acres of federal lands in the 

Background 

Page 6 GAO-09-277 Good Neighbor Authority 
 

contiguous United States place these lands at an elevated risk of severe 

wildland fire. 

The rapid urbanization of forested land in Colorado and Utah has raised 

concerns about the unhealthy condition of forests in those states and the 

potential for resulting wildland fires. These forests also have undergone 

insect and disease attacks of epidemic proportions, further weakening 

them and contributing to the abundance of fuels for wildland fires. For 

example, the mountain pine beetle epidemic now affecting the southern 

Rocky Mountains and other western areas has produced vast areas of dead 

and dying lodgepole pine forests in Colorado and Wyoming. In recent 

years, wildland fires in Colorado and Utah have increasingly threatened 

communities in the interface as well as watersheds (i.e., areas that are 

drained by rivers or other waterways) that provide water to populated 

areas in or near forests. 

The U.S. Forest Service and BLM are the primary federal agencies 

responsible for wildland fire management—together, they oversee about 

450 million acres of forest and rangeland.6

 These agencies take various 

steps to reduce hazardous fuels (fuel reduction) on wildlands, including 

mechanical treatments that use equipment to cut vegetation back to 

desired levels (thinning), planned low-level fires that burn small trees and 

underbrush (prescribed fire), herbicides that kill unwanted vegetation, 

animal grazing, or combined treatments that comprise one or more of 

these methods. Through these efforts, the agencies attempt to restore 

forest and rangeland ecosystems to their historical conditions and reduce 

the risk of severe wildland fires. Like their federal counterparts, some 

state forest services also have an important role in community fire 

prevention. Such agencies maintain crews that suppress wildland fires, 

conduct forest thinning and prescribed burns, advise local landowners on 

ways to build fire-resistant structures, and direct homeowners to local 

contractors who provide fuel reduction services. They also assist in the 

development of community wildland fire protection plans that set 

 

6

Other federal agencies with wildland fire management responsibilities include the Bureau 

of Indian Affairs, Fish and Wildlife Service, and National Park Service, all of which are 

within the Department of the Interior. 

Page 7 GAO-09-277 Good Neighbor Authority 
 

priorities for fuel reduction treatments and recommend specific strategies 

to reduce fire risk on public and private land.7

In addition to efforts to reduce the risk that wildland fires will occur, 

federal and state agencies take other steps to mitigate the impact of 

wildland fires. These steps include projects to stabilize damaged areas and 

rehabilitate them more quickly than would occur under natural conditions. 

Such projects involve activities such as planting native grasses, shrubs, 

and trees; protecting waterways from erosion that could introduce 

sediment into municipal water supplies; and restoring habitat for local fish 

and wildlife populations. 

Attempts at widespread fuel reduction and postfire rehabilitation in the 

wildland-urban interface can be frustrated by the diverse mixture of 

property ownership typically found in this region. A single forest area may 

contain tracts of land that are publicly owned, such as national forests and 

state parklands, as well as tracts that are controlled by a multitude of 

private owners. This mixed-ownership setting creates the potential for 

individual pockets of untreated land to exist within a project area if some 

property owners do not want to join the effort. For example, U.S. Forest 

Service efforts to treat national forest land may be impeded if access to 

these areas is dependent upon consent from private property owners. 

Access to national forest land may also be limited if the project site falls 

within an area where road construction is restricted. In such instances, 

areas left untreated can diminish the effectiveness of the overall project. 

Even if the U.S. Forest Service wanted to join the project, a separate 

contract with the vendor—containing separate requirements for contract 

performance—would typically be necessary. 

Beginning in 1998, the U.S. Forest Service and CSFS began exploring ways 

to manage land across ownership boundaries, particularly in wildlandurban interface areas. The two forest services agreed that management 

activities such as fuel reduction should be undertaken only where 

community interest and support exists, and, thus, these activities would be 

driven largely by state, local, and private projects. To facilitate this work, 

they determined that it would be useful for Colorado state foresters to 

 

7

Under the Healthy Forests Restoration Act of 2003, a community wildfire protection plan 

is a plan—developed primarily by state and local agencies in consultation with interested 

parties and federal land management agencies—that identifies and prioritizes areas in and 

near a community for fuel reduction treatments and recommends the types of treatments 

to be used. 

Page 8 GAO-09-277 Good Neighbor Authority 
 

serve as agents of the U.S. Forest Service for the purpose of conducting 

projects on federal lands immediately adjacent to state, local, or private 

lands where similar work was under way. Colorado’s foresters would be 

authorized to mark boundaries, designate trees for removal, and 

administer other project activities—including sales of designated trees in 

the project area—to reduce fuel risk on federal lands as a complement to 

similar activities on adjacent lands. Because of the collaborative nature of 

these projects, the proposed program became known as “Good Neighbor.” 

In the Department of the Interior and Related Agencies Appropriations 

Act, 2001, Congress established the program, authorizing the U.S. Forest 

Service to allow its state counterpart in Colorado to perform forest, 

rangeland, and watershed restoration services, such as fuel reduction or 

treatment of insect-infected trees, on national forest lands. The services 

provided by the state, either directly or through contracts with private 

vendors utilizing state contracting procedures, were permitted when 

similar and complementary activities were being performed on adjacent 

state or private lands. According to the subsequent agreement signed by 

representatives of the two forest services, the following benefits were 

anticipated from Good Neighbor authority: 

• national forest, state, and private lands would be at less risk from 

catastrophic wildland fire; 

• fuel treatments would provide defensible space for firefighters to occupy 

while combating fires moving from forests to developed areas, or vice 

versa; 

• an impediment to cross-boundary watershed restoration activities would 

be removed, resulting in greater protective and restorative 

accomplishments; and 

Page 9 GAO-09-277 Good Neighbor Authority 
 

• CSFS and the U.S. Forest Service would demonstrate cooperation as 

encouraged in the National Fire Plan, the federal government’s wildland 

fire management strategy.8

Congressional reauthorization of Good Neighbor authority in 2004 added 

BLM areas in Colorado to the authority’s scope. In addition, the 2004 

legislation authorized the U.S. Forest Service to work with Utah’s forest 

service to perform similar watershed restoration and protection projects 

in Utah. Unlike the authorizing legislation for Colorado, however, there 

was no provision in the authorizing legislation for Utah requiring Good 

Neighbor projects to correspond to similar and complementary activities 

under way on adjacent state or private lands. 

The U.S. Forest Service manages 11 national forests in Colorado, within 

the agency’s Rocky Mountain Region, and manages 7 national forests in 

Utah, within the Intermountain Region.9

 Each national forest is divided 

into ranger districts that conduct or oversee “on-the-ground” activities. 

BLM lands in Colorado are managed by the Colorado State Office, which 

in turn oversees BLM field offices across the state. CSFS administers 17 

districts throughout the state, each led by a district forester. UDFFSL, a 

unit of the state’s Department of Natural Resources, is divided into six 

areas, each administered by an area manager.10

 

8

The National Fire Plan comprises multiple documents, including (1) a September 2000 

report from the Secretaries of Agriculture and the Interior to the President in response to 

the wildland fires of 2000, (2) congressional direction accompanying substantial new 

appropriations in fiscal year 2001, and (3) several strategies to implement all or parts of the 

plan. For a description of these documents and their contents, goals, and relationships to 

one another, see GAO, Severe Wildland Fires: Leadership and Accountability Needed to 

Reduce Risks to Communities and Resources, GAO-02-259 (Washington, D.C.: Jan. 31, 

2002). 

9

Several of these forests have been combined into larger administrative units composed of 

two or more forests. In this report, we discuss national forests individually, except where 

noted. 

10For the purposes of this report, we refer to UDFFSL’s six administrative areas as 

“districts.” 

Page 10 GAO-09-277 Good Neighbor Authority 
 

Under Good Neighbor authority, 53 projects have been conducted in 

Colorado and Utah as of the end of fiscal year 2008 at a cost to the federal 

government of about $1.4 million. Colorado Good Neighbor projects 

focused on fuel reduction activities, such as tree thinning, mostly in the 

Colorado wildland-urban interface. In Utah, Good Neighbor projects 

focused on the repair of fire-damaged trails and watershed protection and 

restoration. 

In Colorado, 38 projects were conducted under Good Neighbor authority 

from fiscal year 2002, after the authority was granted, through fiscal year 

2008. These projects primarily focused on fuel reduction. CSFS planned 

these projects in conjunction with the U.S. Forest Service or BLM, as well 

as private owners, and then contracted with private vendors or state crews 

to perform the work on U.S. Forest Service or BLM land. Of these 38 

projects, 29 were on U.S. Forest Service land. These 29 projects included 

fuel reduction treatment on about 2,400 acres in 5 of the 11 national 

forests in the state—the Arapaho, Pike, Roosevelt, San Isabel, and San 

Juan National Forests––with 25 of the projects conducted in the Pike and 

San Isabel National Forests. The remaining 9 Good Neighbor projects 

occurred on forested BLM land covering about 100 acres in Boulder 

County.11 The number of acres being treated under individual Good 

Neighbor projects on U.S. Forest Service land in Colorado ranged from 1 

acre to about 300 acres and on BLM land ranged from 2 acres to 21 acres. 

Figure 1 depicts the number of Good Neighbor projects in each of the 

Colorado national forests and BLM areas. 

Fifty-three Good 

Neighbor Projects 

Have Been Conducted 

in Colorado and Utah 

for Fuel Reduction 

and Other Purposes 

Colorado Good Neighbor 

Projects Focused on Fuel 

Reduction 

 

11Our count of “projects” includes those Good Neighbor projects that have been initiated 

under an agreement or task order between the federal agency and the state; projects can be 

subsequently modified to change the cost, scope, or schedule of work. In addition, 

“conducted” projects include all that have received approval by CSFS and the U.S. Forest 

Service or BLM as of fiscal year 2008, whether planned, initiated, or completed. 

Page 11 GAO-09-277 Good Neighbor Authority 
 

Figure 1: Good Neighbor Projects in Colorado, by National Forest and BLM Area 

Costs to the U.S. Forest Service for the 29 projects conducted on its land 

in Colorado have totaled about $679,000 through fiscal year 2008, while 

costs to BLM for its 9 projects in Boulder County have totaled $74,000 

through the same time period. Individual project costs in Colorado varied, 

ranging from a low of $7,000 to a high of $233,000, depending on the 

number of acres treated and the type of work and equipment required. For 

example, one U.S. Forest Service district ranger stated that in a typical 

tree-thinning project, the contractor would pile and burn the cut branches 

and other thinned material (known as slash) resulting from the work, 

which is relatively inexpensive, but when the work is done in close 

proximity to homes, it usually requires more expensive treatments and 

means of disposal, such as mechanical grinding or chipping. 

Denver

Routt Boulder County (9)

White River

Rio Grande

National forests with Good Neighbor projects

National forests without Good Neighbor projects

BLM areas with Good Neighbor projects

Sources: Map Resources (map); U.S. Forest Service.

Uncompahgre

Boulder

Roosevelt (1)

Arapaho

(1)

Pike (9) Grand Mesa

Gunnison

San Isabel (16)

San Juan

(2)

COLORADO

Page 12 GAO-09-277 Good Neighbor Authority 
 

In Colorado, Good Neighbor projects have been initiated as part of larger 

fuel reduction efforts being planned or conducted by the state on state, 

local, and private land in the state’s wildland-urban interface. The Good 

Neighbor project portion is usually smaller—in acres and cost—than the 

overall fuel reduction effort in a given area. For example, in the upper 

South Platte region, which includes portions of the Pike National Forest, 

CSFS has reduced fuels on thousands of acres in highly fire-prone areas on 

Denver Water12 land and other privately owned land after a severe fire in 

1996 caused extensive sediment runoff into a primary Denver water 

source. However, a portion of these lands was adjacent or intermingled 

with Pike National Forest land, making it difficult to effectively treat the 

entire area without conducting work on federal land. According to CSFS 

officials, the state, as a result of the Good Neighbor authority, was able to 

contract with individual vendors to perform the work required on several 

hundred acres of the Pike National Forest as well as on private lands, 

thereby ensuring a seamless fuel reduction effort across Denver Water, 

private, and U.S. Forest Service lands. Figure 2 shows a slash pile on a fuel 

reduction project site in the Pike National Forest. 

 

12Established in 1918, Denver Water is Colorado’s oldest and largest water utility. Its board 

is responsible for ensuring a continuous supply of water to the city and county of Denver 

and to the nearly 50 percent of Denver Water customers who live in the surrounding 

suburbs. 

Page 13 GAO-09-277 Good Neighbor Authority 
 

Figure 2: Completed Fuel Reduction Project in Pike National Forest with Slash Piled 

for Burning 

In most Good Neighbor projects, the state either performs the services or 

contracts with vendors under a service contract; however, several projects 

in Colorado on U.S. Forest Service land were conducted under timber sale 

contracts in which fuel reduction projects aimed at thinning forests are 

structured as timber sales. Acting through Good Neighbor authority, state 

foresters sold the timber to professional loggers or, in some cases, to 

residents of adjacent subdivisions who used it for firewood. Instead of 

having to pay fuel reduction contractors to remove the timber, the U.S. 

Forest Service received a small amount of sale revenue from the state and 

paid only for the state forester’s administration of the sale.13 Of the 29 

Good Neighbor projects the CSFS has conducted in Colorado on U.S. 

Forest Service land, 15 were conducted in the San Isabel National Forest 

Source: GAO.

 

13This administrative role includes duties such as advertising the sale, determining the 

volume of timber on site, and monitoring the buyer’s work after the contract is awarded. 

Page 14 GAO-09-277 Good Neighbor Authority 
 

and 1 was conducted in the Pike National Forest using timber sale 

contracts.14 Through these timber contracts, about 345,000 cubic feet of 

timber has been harvested and sold as of September 30, 2008, for a total of 

about $19,000.15 According to CSFS officials, the amount received for the 

timber is relatively small because the ponderosa pine, lodgepole pine, and 

mixed conifer timber primarily found in the Pike and San Isabel National 

Forests is small and of low value, as is timber in much of the rest of 

Colorado, in part, because of limited markets for timber. 

In addition, in 3 of the 13 Good Neighbor projects that involved service 

contracts on U.S. Forest Service land, timber sales were included as part 

of the service contract, rather than in a separate timber sale contract. As 

an incentive to attract bidders for these projects, timber harvested during 

fuel reduction was permitted to be removed from the forest and sold to 

local mills, rather than cut and piled on-site. Because prospective bidders 

contemplated the value of this timber in their bids, the cost of the resulting 

service contract was likely lower than it would have been without the 

incentive. For 2 of these projects, 1 located in the San Juan National 

Forest and the other located in the Arapaho National Forest, the total 

volume and value of included timber was 278 CCF for $1,378 and 1,312 

CCF for $5,472, respectively.16

 

14As of September 30, 2008, 11 of these timber sales had been completed or closed, 1 was 

under way, and 4 were in the planning stage. 

15The U.S. Forest Service’s standard unit of measure for wood products is 100 cubic feet, or 

1 CCF. Thus, 345,000 cubic feet of timber would be measured as 3,450 CCF. The total 

amount of timber and associated value from these sales is based on data obtained from the 

U.S. Forest Service’s Timber Sale Accounting System. For more information on this 

system’s process for tracking and accounting for timber, see GAO, Federal Timber Sales: 

Forest Service Could Improve Efficiency of Field Level Timber Sales Management by 

Maintaining More Detailed Data, GAO-07-764 (Washington, D.C.: June 27, 2007). 

16Information on the value of the timber removed on a third project located in the San Juan 

National Forest was not included in the timber contract. 

Page 15 GAO-09-277 Good Neighbor Authority 
 

In Utah, 15 projects have been conducted under Good Neighbor authority 

from fiscal year 2005, when the authority was enacted, through fiscal year 

2008. All of the projects in Utah have been conducted in one national 

forest––the Dixie National Forest—which is in the southern part of the 

state. According to a U.S. Forest Service Intermountain Region official, 

U.S. Forest Service ranger district officials in the Dixie National Forest 

and UDFFSL Southwestern Area officials have historically had a good 

relationship with each other and thought Good Neighbor projects could be 

beneficial to both. As a result, U.S. Forest Service officials in this district 

decided to use Good Neighbor authority to conduct several projects that 

they had originally planned to undertake themselves. Figure 3 depicts the 

national forests located in Utah and the number of projects undertaken in 

the one forest that has used the authority. 

Utah Good Neighbor 

Projects Focused on 

Rehabilitation of Burned 

Areas and Watershed 

Health 

Page 16 GAO-09-277 Good Neighbor Authority 
 

Figure 3: Good Neighbor Projects in Utah, by National Forest 

The types of Good Neighbor projects in Utah are more diverse than those 

in Colorado. Unlike Colorado, where the projects are generally driven by 

overall state fuel reduction initiatives, in Utah, the U.S. Forest Service 

initiates projects and then obtains the assistance of UDFFSL to perform 

work on national forest land. According to Utah state officials, of the 15 

Good Neighbor projects conducted in Utah, only 2 projects were fuel 

reduction-related, where state crews burned piles of brush and slash on 

over 300 acres near adjacent private lands to assist the U.S. Forest Service 

in a larger fuel reduction project in the forest. Of the remaining 13 

projects, 8 involved using state crews or contractors to rehabilitate burned 

National forests without Good Neighbor projects

National forests with Good Neighbor projects

Dixie (15)

Manti-LaSal

UTAH

Fishlake

Uinta

Ashley

Wasatch

Cache

Wasatch

Salt Lake City

Sources: Map Resources (map); U.S. Forest Service.

Page 17 GAO-09-277 Good Neighbor Authority 
 

areas following wildland fires, including activities such as repairing and 

constructing fences, cleaning impoundments used by cattle and wildlife, 

and reconstructing forest trails. In the 5 remaining Good Neighbor 

projects, the state used crews or contractors to protect the watershed 

from erosion and sediment runoff by, for example, rehabilitating trails 

used by all-terrain vehicles and transportation and placement of large 

barrier rocks on either side of a roadway near public campsites to prevent 

vehicles from traveling off-road and damaging forest resources (see fig. 4). 

Figure 4: Barrier Rocks Placed along Dixie National Forest Roadway to Prevent Offroad Vehicle Use 

Costs to the U.S. Forest Service for these 15 projects have totaled about 

$674,000 through fiscal year 2008. As in Colorado, costs varied depending 

on the type of work and equipment provided. For example, project costs 

ranged from $1,500 for a pile burning on a few acres to $174,000 for 

replacement of existing culverts—large pipes that allow natural waterways 

to flow under road crossings—with new structures that will improve the 

forest watershed by facilitating the passage of trout and other fish species. 

Source: GAO.

Page 18 GAO-09-277 Good Neighbor Authority 
 

State procedures are used for projects that involve service contracts, 

which include most Good Neighbor projects to date, while projects that 

include timber sales incorporate both state and federal requirements. We 

examined both states’ contracting requirements concerning three 

fundamental principles of government contracting—transparency, 

competition, and oversight—and found that state requirements generally 

address each of these areas. The U.S. Forest Service and CSFS are 

currently updating their Good Neighbor timber sale procedures, however, 

to make certain that timber sales conducted under the authority include all 

protections that federal officials believe are necessary when dealing with 

federal timber. Neither BLM in Colorado nor the U.S. Forest Service in 

Utah has developed written procedures for conducting Good Neighbor 

timber sales, primarily because neither agency has sold timber under the 

authority. However, such procedures could help ensure accountability for 

federal timber if these agencies conduct such sales in the future. 

State procedures generally govern Good Neighbor projects that involve 

service contracts, which include 37 of the 53 Good Neighbor projects to 

date. Good Neighbor projects are initiated under the authority of Good 

Neighbor agreements between each state and federal agency, which 

describe at a high level the authority and responsibilities of each agency in 

conducting projects, including the project’s planning, design, preparation, 

contracting, and administration.17 For those projects involving service 

contracts, Good Neighbor agreements allow the states to use their own 

procedures to enter into contracts with vendors that provide services, 

such as fuel reduction, in conducting forest restoration projects, or the 

states may use their own crews to carry out the work. Under the 

agreements, however, the U.S. Forest Service and BLM retain certain 

authorities when Good Neighbor projects are conducted. For example, for 

projects carried out on their respective lands, the U.S. Forest Service and 

BLM remain responsible for ensuring that the requirements of NEPA are 

satisfied. Once NEPA requirements are satisfied and project planning is 

completed, the state and federal agencies develop a task order for each 

project, detailing its objectives and cost.18 The state can then proceed with 

Good Neighbor 

Projects Are 

Generally Governed 

by State Procedures, 

but Projects Involving 

Timber Sales Also 

Incorporate Certain 

Federal Requirements 

State Procedures Are 

Generally Used for 

Projects That Involve 

Service Contracts 

 

17The U.S. Forest Service has Good Neighbor “master” agreements in place with Colorado 

and Utah, and also initiates separate agreements, referred to as “task orders,” for each 

Good Neighbor project. BLM has initiated one agreement for its Boulder County fuel 

reduction projects and amends this agreement as projects are modified or added, but has 

no master agreement in place. 

18BLM calls these task orders “agreement modifications.” 

Page 19 GAO-09-277 Good Neighbor Authority 
 

procuring the needed services using its own procurement and contracting 

process. In Colorado, the Colorado State University (CSU) administers 

procurement and contracting for all CSFS service contracts, including 

those for Good Neighbor projects. In Utah, procurement and contracting 

for service contracts are administered and approved by either UDFFSL or 

the Utah Division of Purchasing, depending on the size of the 

procurement. 

We examined CSU’s and the Utah agencies’ contracting requirements 

concerning three fundamental principles of government contracting—

transparency, competition, and oversight. Specifically, we examined each 

state agency’s procurement rules concerning the following practices: 

• soliciting contracts through public notice, with reasonable time allowed 

for potential vendors to develop and offer their bids; 

• ensuring competition, except in cases where there are legitimate 

extenuating circumstances, such as projects for which there is only one 

responsive bidder; 

• using simplified acquisition procedures for contracts whose dollar value is 

below a specified amount; 

• awarding contracts to the lowest-priced vendor when evaluating 

competing offers, and requiring justification when any additional criteria, 

such as past performance, are used; 

• giving preference to small businesses when awarding contracts; 

• using fixed-price contracts;19

• avoiding the awarding of contracts to private vendors for the performance 

of inherently governmental functions, such as budgeting and hiring; 

• including worker protection provisions in state contracts; 

• conducting orientation conferences with vendors at project sites; and 

 

19A fixed-price contract provides for a price that is not subject to adjustment on the basis of 

the contractor’s cost experience in performing the contract. 

Page 20 GAO-09-277 Good Neighbor Authority 
 

• providing for ongoing quality control, and requiring the government to 

conduct quality assurance inspections to determine whether the vendor is 

fulfilling the contract. 

In our analysis, we found that the state agencies’ contracting and 

procurement requirements generally address each of these areas. We 

discuss five of these areas in the following text: 

• We found that agencies in both states provide a reasonable amount of time 

to advertise and receive bid proposals as well as provide competition 

among vendors. In CSU procurements, for example, contracts for services 

that will cost between $25,000 and $150,000 are generally advertised on 

Colorado’s Internet bidding system for not less than 3 days—to allow 

vendors time to develop and offer their bids. CSU provides additional 

requirements for procurements relating to CSFS forest-related work, 

allowing a minimum of 14 days for vendors to submit a bid regardless of 

the type of procurement because vendors that may be interested are often 

in the field conducting forest-related work and may not see the 

advertisement for several days. Services that will cost less than $25,000 are 

left to the discretion of the purchasing agent, who may advertise the bid or 

solicit vendors via telephone to determine whether they are interested. 

According to CSU procurement officials in Colorado, competition is 

generally promoted, except in two circumstances: (1) when only one 

vendor is available, and the contract has to be awarded to that vendor, or 

(2) the service being obtained will cost less than $25,000, which allows the 

purchasing agent to obtain services through other state agencies, such as 

the Colorado Corrections Industry, without written justification, if a fair 

market price is obtained. Competition is similarly promoted in Utah, 

according to state contracting officials, but contracting officers in the state 

may use informal procedures to acquire services, if the services will cost 

less than $50,000. For example, to award a $30,000 service contract, the 

state’s centralized Division of Purchasing may solicit telephone bids from 

three known vendors, then select one of the three vendors. This would not 

be an acceptable amount of competition for acquisitions exceeding 

$50,000, which would require the invitation to bid to be disseminated via 

the state’s Internet bidding system for a minimum of 10 days’ bidding time. 

• Agencies in both states are generally required to award a contract to the 

lowest-priced bidder who meets the requirements set forth in the 

solicitation for bids for contracts, except in certain circumstances, such as 

when contracts are sizable enough to require a request for proposal—in 

which the state requires bidders to address additional criteria in their bids, 

such as technical requirements—or when strong justifications for not 

choosing the lowest bidder can be documented by the contracting officer. 

Page 21 GAO-09-277 Good Neighbor Authority 
 

Additional requirements are imposed by the state agency to ensure that 

contracts are awarded to reputable contractors. For example, contract 

terms and conditions in both states require contractors to certify that they 

have not been debarred, suspended, or proposed for debarment by any 

governmental department or agency. In addition, for all proposed 

contracts that are federally funded, including Good Neighbor contracts, 

CSU purchasing agents search for prospective vendors’ names on the 

General Services Administration’s Excluded Parties List System, which is a 

database for obtaining information on parties that are excluded from 

receiving federal contracts, certain subcontracts, and certain federal 

financial and nonfinancial assistance and benefits. If a prospective vendor 

is on the list, the CSU purchasing agent will not consider this vendor’s bid, 

even if it is the lowest priced. 

• According to state agency officials, the procurement policies of agencies 

in both states encourage contracting for services with small or 

disadvantaged businesses, although there are no specific set asides for 

small or disadvantaged businesses in either state. A CSU official stated 

that CSU promotes such businesses through a small business program, 

and that about 90 percent of CSFS contracts, including contracts for Good 

Neighbor projects, go to small businesses. However, attaining this 

percentage is not a requirement, according to this official, but simply 

results from the fact that types of work required in forest restoration 

projects, such as fuel reduction, are typically performed by small 

businesses. A Utah Division of Purchasing official stated that, although set 

asides are not required in Utah, the state will incorporate them into any 

procurement if the federal government requires set asides as the condition 

of a particular grant or contract under which the procurement is 

conducted. The official added that the federal government, rather than the 

state, is ultimately responsible for determining whether contracts are 

awarded pursuant to federal requirements for small businesses. 

• According to state agency officials in both states, contractors are generally 

required to have liability insurance. In addition, the state agencies 

incorporate federal worker protection provisions into state contracts as 

requested by federal agencies. For example, the Migrant and Seasonal 

Agricultural Workers Protection Act20 is a federal law that applies to 

migrant and seasonal agricultural workers, including at least some forestry 

 

20The act, 29 U.S.C. §§ 1801-1872, was enacted to eliminate activities that are detrimental to 

migrant and seasonal agricultural workers, to require registration of farm labor contracts, 

and to ensure necessary protections for workers. 

Page 22 GAO-09-277 Good Neighbor Authority 
 

workers.21 While none of the agencies we reviewed specifically requires 

that the act’s provisions be explicitly included in state contracts, 

procurement officials in both states said that they include such federal 

provisions if they are conditions of grants or are otherwise stipulated in 

federal-state agreements. 

• The responsibility for monitoring contract performance—through 

activities such as project site visits to ensure satisfactory work and a 

quality assurance inspection at the job’s completion—is largely left to the 

state forest services’ project managers in the field. However, both states 

use contract mechanisms to ensure that a vendor’s performance meets 

government standards, including performance bonding and requirements 

that contractors operate within an agency-approved scope of work. 

In reviewing state requirements concerning transparency, competition, 

and oversight, we compared selected state procurement and contracting 

requirements with those in the Federal Acquisition Regulation (FAR), 

which governs federal procurement activities, as well as specific U.S. 

Forest Service and BLM procurement guidance, and found them to be 

generally comparable. For example, we reviewed FAR provisions on 

(1) publicizing contract actions, which can include the establishment of a 

minimum bidding period that gives potential vendors a reasonable 

opportunity to respond; (2) competition requirements, which includes a 

requirement to provide for full and open competition through the use of 

competitive procedures, but allows for an exception to these procedures 

in limited circumstances, for example, if there is only one suitable vendor; 

and (3) quality assurance, which details several mechanisms—including 

inspection requirements and contract clauses—for maintaining project 

oversight and ensuring that the government receives quality work. 

Although we did not analyze all portions of the FAR, our broad 

comparison suggests that state and federal procurement requirements are 

generally similar in the areas we examined. 

 

21See Morante-Navarro v. T&Y Pine Straw, 350 F.3d 1163, 1170-72 & n.4 (11th Cir. 2003) 

(and cases cited). 

Page 23 GAO-09-277 Good Neighbor Authority 
 

While most Good Neighbor projects are carried out through service 

contracts, certain CSFS districts in Colorado, such as the Salida District, 

also use timber sale contracts to conduct fuel reduction projects when the 

project is expected to involve the harvest of merchantable timber. In such 

cases, CSFS Good Neighbor timber operating procedures incorporate 

certain federal requirements beyond those used for ordinary state timber 

sales, to ensure proper oversight of, and accountability for, state removal 

of federal timber. For example, the following additional project 

requirements are included in Good Neighbor timber sale operating 

procedures: 

Projects That Include 

Timber Sales Incorporate 

Both State and Federal 

Requirements 

• state foresters should determine the timber sale volume, using standard 

federal tree sampling methods; 

• state foresters should work with the local U.S. Forest Service ranger 

district to develop a sale appraisal and determine a minimum bid price; 

and 

• project sites with total timber sale volume greater than 25 CCF or values 

greater than $5,000 should be marked with U.S. Forest Service tracer paint 

to identify trees to be cut and boundaries around the area in which cutting 

is to take place. 

CSFS officials, in conjunction with U.S. Forest Service regional officials, 

developed these CSFS timber operating procedures in 2007, in response to 

confusion over the requirements governing timber sales. When Good 

Neighbor authority was first being used, general operating procedures 

were contained in the master agreements, but no specific operating 

procedures existed, and some CSFS district officials were unsure about, or 

unaware of, certain requirements that needed to be followed as part of 

conducting a timber sale on federal land. We reviewed the provisions in 

the initial timber sale contracts that CSFS administered under Good 

Neighbor authority and found that they were not as extensive as standard 

U.S. Forest Service timber sale contracts. For example, the state Good 

Neighbor timber sale contracts did not specifically require the contractor 

to consider additional activities associated with the project, such as road 

maintenance, and did not include information about whether threatened 

and endangered species were in the project area. In addition, these 

contracts did not include detailed descriptions of the type and amount of 

timber sold. This type of information was included in standard U.S. Forest 

Service timber sale contracts. CSFS’s recent operating procedures address 

these issues, and a U.S. Forest Service Rocky Mountain Region official 

told us that CSFS has begun to include some of this information in more 

Page 24 GAO-09-277 Good Neighbor Authority 
 

recent timber sale contracts—for example, CSFS included a clause 

addressing threatened and endangered species in a recent timber sale 

contract. 

Some U.S. Forest Service officials told us, however, that they remain 

concerned about certain aspects of timber sales conducted under Good 

Neighbor authority. Accordingly, the U.S. Forest Service and CSFS are 

drafting additional timber procedures that were not addressed in the initial 

procedures in 2007. These revised operating procedures add or revise 

procedures that identify federal and state roles in Good Neighbor timber 

sales from the initial NEPA documentation through the sale and 

subsequent harvesting of national forest timber. For example, the agencies 

are considering adding procedures for better accountability of timber sales 

by outlining the necessary information that needs to be included in the 

U.S. Forest Service’s Timber Information Management System, a system 

which tracks all information connected with each federal timber sale from 

its inception to completion. These provisions are currently in draft form, 

but when finalized will be considered joint operating procedures for both 

agencies. 

In addition, the U.S. Forest Service has already begun initiating some 

changes to the timber sale contract requirements in its latest Good 

Neighbor projects. According to a U.S. Forest Service official, one 

important change to the procedure is that national forest timber will be 

considered as “sold” first to the state, which in turn will sell it to the 

private contractor. According to a CSFS official, project task orders for 

timber sale contracts will clearly specify any special U.S. Forest Service 

contract requirements that are the responsibility of the state, which in turn 

will hold the contractor accountable for meeting those requirements. With 

this change, the state will more clearly know what special additions they 

must make to their Good Neighbor timber sale contract for a particular 

project. State officials believe this change will improve the project 

administration by the state and the accountability for enforcing certain 

U.S. Forest Service requirements. For example, an October 2008 Good 

Neighbor timber sale contract between the state and the buyer includes a 

U.S. Forest Service stipulation resulting from the project’s federal NEPA 

analysis, specifically prohibiting logging work from December 1 through 

April 15, to avoid interfering with the winter range of big game animals, 

such as deer and elk. Under the new contracting provisions, the state is 

now responsible for enforcing this provision. 

We did not compare Colorado’s timber sale requirements with those of 

BLM, or Utah’s with those of the U.S. Forest Service, because neither BLM 

Page 25 GAO-09-277 Good Neighbor Authority 
 

in Colorado nor the U.S. Forest Service in Utah has conducted timber 

sales under Good Neighbor authority to date, and neither BLM in Colorado 

nor the U.S. Forest Service in Utah has developed written procedures for 

doing so. According to a CSFS official, detailed operating procedures for 

BLM Good Neighbor projects have not been developed because CSFS’s 

experience with the agency—consisting of nine projects in Boulder 

County at a total cost of $74,000—has been too limited to justify spending 

time and resources in developing such procedures. In addition, a BLM 

official stated that if the agency decided to have CSFS conduct timber 

sales as part of its Good Neighbor projects, it would likely require CSFS to 

utilize a BLM timber sales contract on the basis of agency timber sale 

requirements, or work with CSFS to ensure that the necessary federal 

requirements were accounted for in a state timber sales contract. As for 

Utah, a senior UDFFSL official told us that there is no official UDFFSL 

timber sale contract or process, because neither UDFFSL nor its parent 

Department of Natural Resources is involved in the sale of state timber. 

Instead, this is the role of a separate state agency that administers real 

estate trusts granted to Utah at statehood and is not involved in Good 

Neighbor projects. UDFFSL has developed a sale contract template for 

private landowners to use when selling timber from their land to 

commercial loggers. If timber were sold as part of a Good Neighbor 

project in Utah, a senior UDFFSL official speculated that agency managers 

in the field might use this contract template in the absence of other 

guidance. 

Although the value of timber removed through Good Neighbor projects 

has been minimal, the agencies’ experiences in using the authority to sell 

timber have demonstrated the importance of having detailed Good 

Neighbor timber sale operating procedures. Such procedures can help 

ensure that officials in both the federal and state agencies understand each 

agency’s roles and responsibilities and can help provide the guidance 

necessary to ensure proper accountability for federal timber. Should BLM 

in Colorado or the U.S. Forest Service in Utah decide to undertake timber 

sales through Good Neighbor authority in the future, or should the 

authority be expanded to include other states where such timber sales 

might occur, both federal and state agencies would benefit from written 

procedures detailing each party’s responsibilities in conducting Good 

Neighbor project timber sales. 

Page 26 GAO-09-277 Good Neighbor Authority 
 

Federal and state officials who have participated in Good Neighbor 

projects cited project efficiencies as the authority’s primary benefit, 

including the ability to begin work more quickly and to reduce hazardous 

fuels across multiple ownerships with a single contract. The authority also 

provides a forum for federal-state cooperation that can aid other 

collaborative efforts, such as emergency wildland fire suppression. 

Challenges encountered by the agencies include federal and state officials’ 

incomplete understanding of how projects should be administered under 

the authority and concern about the adequacy of state contract 

procedures. Future use of Good Neighbor authority may benefit from 

documentation of agency experiences in using the authority to date, 

particularly since stakeholders told us that the authority’s chances for 

success in other states hinge on several factors, including the structure, 

staffing levels, and workloads of other state forest services, as well as the 

characteristics of those states’ federal lands. 

Federal and state officials who have used Good Neighbor authority cited 

project efficiencies as its primary benefit. The efficiencies cited include an 

ability to begin work more quickly, in part because the Colorado and Utah 

state forest services have established relationships with local communities 

and in part because state contracting procedures are considered to be 

simpler than federal procedures. In Colorado, for example, CSFS’s mission 

includes a mandate to assist local property owners with forest 

management on their lands. The state agencies’ resulting familiarity with 

local communities extends to knowledge of local vendors that offer 

services such as fuel reduction, which—combined with the states’ 

simplified contracting procedures—can shorten the time required to 

identify a suitable contractor, secure a contract, and begin work. 

According to one U.S. Forest Service district ranger in Colorado, this type 

of local-level coordination with private landowners and local contractors 

is not a specialty of most ranger districts’ staff. The state foresters’ 

familiarity with local landowners also speeds implementation when access 

is required across private land to reach a project site on federal land—for 

example, when a project site is far from existing forest roadways but is 

near a network of private roads within a subdivision. In one such instance, 

the U.S. Forest Service needed to gain access through a private 

subdivision to treat a densely forested area in an adjoining national forest. 

As part of a Good Neighbor agreement, CSFS negotiated with the 

subdivision’s owners to gain access to the site so that a private contractor 

could begin work. Figure 5 shows a map of the project area. 

Experiences with 

Good Neighbor 

Authority to Date 

Could, If Better 

Documented, Provide 

Insight for Potential 

Expansion of Its Use 

Benefits of Good Neighbor 

Authority Include Project 

Efficiencies and Increased 

Federal-State Cooperation 

Page 27 GAO-09-277 Good Neighbor Authority 
 

Page 28 GAO-09-277 Good Neighbor Authority 

Figure 5: Fuel Reduction Project Site in National Forest Area Bordering Private 

Subdivision 

Note: The project area was divided into four units and numbered in order of priority. 

According to state officials, securing this access is often less timeconsuming for state foresters because, as a result of their state agencies’ 

emphasis on local outreach, they are often better known in the community 

Unit 3

19 acres

Unit 2

41 acres

Unit 1

61 acres

Unit 4

14 acres

Source: GAO adaptation of Colorado State Forest Service map.

National 

forest

Access

roads

Private

subdivision
 

than their federal counterparts. Moreover, several state officials noted that 

the U.S. Forest Service sometimes attempts to secure a permanent 

easement across private land in this scenario, which is less likely to result 

in a landowner’s cooperation, instead of temporary access for the duration 

of a specific project. 

The ability to begin work more quickly can be important when Good 

Neighbor projects use funding that is only available for the remainder of 

the current fiscal year. (Good Neighbor projects do not receive dedicated 

funding; instead, projects are funded from a variety of accounts, including 

grant funds.) In certain cases, the U.S. Forest Service decides to fund a 

project for one field unit near the end of the fiscal year—for example, by 

shifting funds from another field unit that has no further fuel reduction 

activities to fund that year. Partnering with the state forest service through 

a Good Neighbor agreement that expedites contracting can allow the 

project to be started prior to the end of the current fiscal year. 

In some cases, according to federal and state officials, using state foresters 

to administer Good Neighbor projects increased the efficiency of federal 

activities because the state was willing to assume responsibility for project 

administration. For example, state foresters in Utah performed project 

management duties, such as locating responsible vendors, negotiating 

contracts, and processing payments to vendors as work progressed. 

According to Utah officials, the state forest service was willing to 

undertake these Good Neighbor project duties because the projects 

benefited shared watersheds, accomplished important work for 

communities, and had a positive impact on local economies. Similarly, 

Colorado’s state forest service administered Good Neighbor fuel reduction 

projects in the state’s South Platte district under an arrangement funded 

by Denver Water, which benefited from the resulting watershed 

protection. In other cases, because the state structured fuel reduction 

projects as timber sales, fees related to the state forester’s administration 

of these sales were the only costs to the federal government—there were 

no service costs. 

The use of Good Neighbor authority also increased the effectiveness of 

fuel reduction treatments in areas that include federal, state, and private 

ownership and helped to maximize the degree of wildland fire risk 

reduction per dollar spent on the project, according to agency officials. 

Arranging for a single vendor to perform the work across ownership 

boundaries increased the likelihood that forest treatment was conducted 

in a uniform way and avoided leaving untreated land parcels in the project 

area. According to one U.S. Forest Service official, the ability to treat land 

Page 29 GAO-09-277 Good Neighbor Authority 
 

parcels under multiple ownerships is critical because fire “doesn’t know 

the boundary” between federal, state, and private forest land. 

Given the advantages of partnering with the state—including the ability to 

negotiate access agreements, find suitable vendors, utilize more nimble 

contracting procedures, and share some project management duties—the 

use of Good Neighbor authority allowed the agencies to accomplish more 

than they would have accomplished in the absence of the authority, 

according to officials with whom we spoke. As U.S. Forest Service officials 

in Utah noted, the ability to leverage state employees to work on national 

forest lands increases the number of initiatives that a manager can 

undertake. For example, the Cedar City ranger district in the Dixie 

National Forest enlisted the state to reconstruct an all-terrain vehicle trail 

running through the forest, adding a layer of gravel to prevent trail erosion 

from continuing to spread sediment into nearby wetlands. According to 

the project’s federal manager, U.S. Forest Service crews’ already heavy 

workload was one reason for giving the project to the state. A second 

reason was UDFFSL’s ability to employ a county road crew on the project 

that would do similar work on private portions of the trail that access 

nearby communities.22 In other cases, projects benefiting local 

communities may “fly under the [U.S.] Forest Service’s radar,” as one state 

official said. That is, due to their inaccessible location or relatively small 

size, the national forest portions of some fuel reduction projects may not 

have been part of the U.S. Forest Service’s annual work plan until the state 

proposed including the parcels in landscapewide projects being planned 

for state and private property. Using state crews and private companies to 

do this work has additional advantages. For example, state and federal 

officials in Utah said that employing seasonal state fire response personnel 

on Good Neighbor projects brings revenue to the state that allows it to 

maintain these personnel for a longer period, keeping them available for 

emergency fire response outside of the state’s peak summer fire season. 

On the other hand, having the state contract with private companies 

allows the skills needed for necessary work such as fuel reduction to 

develop within a community, increasing the number of potential vendors 

that are qualified to work with federal agencies in the future. 

 

22According to a contracting officer in Utah’s Division of Purchasing, state agencies are 

permitted to enter into agreements with other agencies and with political subdivisions of 

the state, such as counties, outside of the standard state contracting process. The state 

presumes that two of its government entities collaborating on a project will be less costly 

and more efficient than hiring a private contractor, because there is no profit motive. 

Page 30 GAO-09-277 Good Neighbor Authority 
 

In addition to creating project and agency efficiencies, the use of Good 

Neighbor authority provided a forum for collaboration between federal 

and state agencies that officials told us can increase the effectiveness of 

other cooperative efforts. For example, emergency suppression of 

wildland fires demands that agency officials be able to coordinate under 

tight time and resource constraints with representatives of many different 

governmental entities. According to federal and state officials, this 

coordination is made easier by past working relationships on collaborative 

projects, such as those conducted under Good Neighbor authority that 

develop familiarity and instill mutual trust. This collaboration is useful 

outside of emergency scenarios as well. Officials identified stewardship 

contracting—where agencies use other special contracting authorities, 

such as the exchange of timber for fuel reduction services, to meet 

community land management needs—as another initiative that can benefit 

from a shared history of cooperation on Good Neighbor projects.23

Federal and state agencies have also encountered challenges in using 

Good Neighbor authority, including a lack of understanding of the 

authority that has complicated partnerships between federal and state 

officials. In Colorado, several state foresters said that their initial attempts 

to interest their U.S. Forest Service counterparts in potential projects were 

hampered by the federal officials’ lack of familiarity with the authority. In 

some of these areas, projects were eventually undertaken, but confusion 

about roles and responsibilities made project implementation more 

difficult—especially for projects involving timber sales. In Utah, projects 

have been conducted by only one national forest, in partnership with one 

of the state’s six districts. State officials in two of Utah’s remaining 

districts reported that they have encountered a lack of awareness of the 

authority from their prospective federal counterparts, similar to the early 

years of Colorado’s Good Neighbor experience. 

Likewise, concern over the adequacy of state contracting procedures 

hampered the use of the authority. Some U.S. Forest Service officials in 

Colorado considered state timber sale procedures to be insufficient to 

Challenges in Conducting 

Projects Include Lack of 

Understanding of the 

Authority and Concern 

about Adequacy of State 

Contract Procedures 

 

23For more information about stewardship contracting, see GAO, Federal Land 

Management: Additional Guidance on Community Involvement Could Enhance 

Effectiveness of Stewardship Contracting, GAO-04-652 (Washington, D.C.: June 14, 2004); 

and Federal Land Management: Use of Stewardship Contracting Is Increasing, but 

Agencies Could Benefit from Better Data and Contracting Strategies, GAO-09-23 

(Washington, D.C.: Nov. 13, 2008). 

Page 31 GAO-09-277 Good Neighbor Authority 
 

protect federal interests and imposed additional contracting requirements 

on the state before agreeing to Good Neighbor projects. For example, in 

one Colorado district, a state forester’s agreement with the local U.S. 

Forest Service ranger district staff about how to proceed on an early Good 

Neighbor project was overruled by the ranger district’s regional 

management, which placed additional requirements on the project. The 

regional office did not approve of some of the state’s processes—such as 

the state’s appraisal of timber value, and the way the state’s timber 

contract was written—and asked that additional requirements be included 

to ensure that the state could account for any federal timber removed. 

This request resulted in two separate contracts with the project’s single 

vendor—one for work being done on U.S. Forest Service land, and a 

second for work being done on private land. In another state district, a 

state forester who coordinated Good Neighbor projects for two ranger 

districts on the same national forest found that project requirements in 

one ranger district were more rigorous than for those in the other. In the 

latter district, the ranger allowed the state forester to administer projects 

involving timber sales using state contracting processes; however, the 

ranger in charge of the first district required that the U.S. Forest Service 

have more involvement in administering that district’s sale, believing that 

the U.S. Forest Service’s timber sale procedures did a better job of holding 

contractors accountable for their project performance than did state 

contracting procedures. 

Some state and federal officials found the overlay of federal requirements 

burdensome, making them less likely to participate in Good Neighbor 

projects. In one state district where U.S. Forest Service regional 

management imposed additional federal requirements on early projects 

because of doubts about the sufficiency of state procedures, state officials 

expressed a reluctance to pursue future projects until differences between 

the federal and state approaches are resolved. A former U.S. Forest 

Service official involved in this district’s projects said that the region’s 

additional requirements were counter to Good Neighbor’s core philosophy 

of landscape-level management requiring one appraisal, one vendor, and 

one contract. A second federal official added that the timber involved in 

these projects was of such little value that the attempt to add additional 

time-consuming accountability procedures was not cost-effective. State 

officials in the district and their federal counterparts have not pursued 

additional Good Neighbor projects to date, but state officials noted that 

timber sale procedures have been streamlined in the years since they 

experienced their early difficulties. 

Page 32 GAO-09-277 Good Neighbor Authority 
 

In addition, the CSFS official in charge of coordinating Good Neighbor 

projects for the state said that the cumbersome administrative process 

imposed by both CSU and the U.S. Forest Service has effectively 

eliminated the use of Good Neighbor authority for small-scale projects in 

Colorado, frustrating an important original intent of the program. This 

process often makes such activities—for example, allowing an individual 

landowner to expand fuel reduction treatments onto U.S. Forest Service 

land to remove insect-infested trees or to establish an adequate defensible 

space for improved wildland fire protection—too burdensome and timeconsuming to pursue. According to the CSFS official, both CSFS and U.S. 

Forest Service timber staff have recognized the need to streamline the task 

order approval process to address this problem if Good Neighbor 

authority is extended. 

According to several federal and state officials, a lack of detailed guidance 

in the early years of using Good Neighbor authority created confusion over 

the respective duties of federal and state project participants. In Colorado, 

federal and state officials issued general project guidelines as part of their 

Good Neighbor master agreement that addressed general operating 

procedures, but did not provide specific project-level direction—

particularly concerning the use of timber sales in fuel reduction projects. 

As we have previously mentioned, more detailed guidance specifically 

addressing timber sales was issued in 2007, as a result of lessons learned 

from projects involving such sales and in recognition of the fact that sale 

procedures being used in some ranger districts differed from those used in 

others. These procedures are now being revised by the U.S. Forest Service 

and CSFS to address unresolved issues, such as how Good Neighbor 

timber sales should be reported in the U.S. Forest Service’s performance 

and financial tracking systems. The revised guidance—now in draft form—

also includes additional timber accountability procedures. In Utah, U.S. 

Forest Service and state officials agreed on general project guidelines, but 

they have not issued more detailed guidance for project implementation, 

including instructions regarding timber sales. Although such instructions 

have not been needed to date because no timber sales have occurred 

under Good Neighbor authority in Utah, the area manager for the one state 

district where Good Neighbor projects have been conducted said that 

future projects may include timber sales. In addition, an area manager in 

another Utah district said that he had approached his U.S. Forest Service 

counterpart with a fuel reduction project proposal involving a timber sale. 

There is no official guidance that encompasses BLM’s Good Neighbor 

project responsibilities on BLM land in Colorado, in part because there 

have been few projects on BLM land. 

Page 33 GAO-09-277 Good Neighbor Authority 
 

The nature of Good Neighbor authorization and funding posed a challenge 

in some districts. Federal and state officials in Utah said that because 

Good Neighbor projects do not receive dedicated funding, money to 

conduct the projects instead comes from supplemental accounts, such as 

funding associated with the National Fire Plan. In the past, such funding 

has arrived several months or more after the beginning of the federal fiscal 

year. This shortens the project window for fuel reduction work, which can 

be especially problematic for projects involving pile burnings or 

prescribed fire because such projects must be completed outside of fire 

season, which can stretch from mid-May to mid-October in the Dixie 

National Forest. Other state officials agreed that the annual federal 

appropriations cycle—which included, for example, reauthorization of 

Good Neighbor authority in Utah for a period of just over 9 months in 

fiscal year 2008—makes long-term project planning more difficult, 

resulting in less Good Neighbor activity. 

Officials in federal and state districts where Good Neighbor projects have 

not been undertaken had various reasons for not using the authority. Some 

foresters said they had not seen opportunities for projects that fit Good 

Neighbor’s criteria, while others lacked staff or other resources. One 

national forest supervisor in Utah saw several advantages to using the 

authority, but he wanted to ensure that his own staff was fully utilized 

before giving work to the state. Conversely, a senior official in Utah said 

that some state foresters see little benefit in adding projects that benefit 

the U.S. Forest Service to their workload, unless they are compensated by 

the U.S. Forest Service for their associated project administration duties. 

Experiences with Good Neighbor authority in Colorado and Utah may 

provide insights for its potential expansion in those and other states. 

Specifically, federal, state, and other stakeholders identified several 

factors that affect Good Neighbor authority’s chances for success, 

including the structure, staffing levels, and workloads of state forest 

services and state purchasing staff, as well as the characteristics of those 

states’ federal lands. These stakeholders noted that while it is important to 

understand the successes and challenges of Good Neighbor authority’s use 

in Colorado and Utah when considering its expansion to other states, it is 

equally important to account for differences among states as well. One key 

difference is the structure and mission of state forest services: whereas 

these agencies in Colorado and Utah emphasize community forestry 

assistance, other states may have different priorities reflecting differences 

in their history, geography, or institutional framework. For example, the 

Idaho Department of Public Lands manages its state’s forest resources to 

Future Use of Good 

Neighbor Authority May 

Be Enhanced by 

Documentation of 

Experiences with the 

Authority to Date 

Page 34 GAO-09-277 Good Neighbor Authority 
 

maximize the revenue from these resources and other state lands through 

activities such as timber harvesting, livestock grazing, and commercial 

building, according to a senior department official; the revenue generated 

from most of these trust lands supports the state’s public schools. Though 

this official could see advantages to having Good Neighbor authority in 

Idaho, such as the ability to conduct uniform land management practices 

across broader areas, she said she would be wary of any activities that 

would divert her agency from its primary mission of managing the state’s 

trust lands. A representative of an environmental group in Idaho told us 

that state forest management practices—such as the focus on timber 

harvesting—could lead to competing priorities if the state manages Good 

Neighbor projects on behalf of the federal government. To avoid this, he 

suggested that roles and responsibilities should be clearly defined at the 

outset for both federal and state participants if Good Neighbor authority is 

extended to Idaho. Moreover, a U.S. Forest Service official in Colorado 

who had previously worked for the relatively small forest service in a 

nearby state said that Good Neighbor’s effectiveness in other states would 

depend on their capacity to implement the agreements and monitor the 

projects within their staffing resources and workload, and that he did not 

think state forest services with limited resources would be able to handle a 

Good Neighbor project workload comparable to Colorado’s. There may 

also be differences in the federal and state forest services’ relationship, the 

strength of which is a major determinant of Good Neighbor project 

success, according to numerous federal and state officials with whom we 

spoke in Colorado and Utah. 

Another major difference among states is the value of timber on their 

lands. While fuel reduction projects undertaken thus far under Good 

Neighbor authority have generally harvested low-value trees in a 

depressed timber market, project sites in other areas of Colorado and 

Utah, or in other states, may contain more valuable timber. Fuel reduction 

projects carried out under Good Neighbor authority in those areas, 

especially those involving timber sales, would likely attract more federal 

timber sale oversight, and might likewise attract additional scrutiny from 

environmental stakeholders concerned that projects were being 

undertaken for their timber value, rather than for ecological necessity. For 

example, representatives of one environmental group in Colorado told us 

they did not have concerns about Good Neighbor projects conducted to 

date, but stated that this is in part due to the low timber value in the 

state—saying “there’s little worry here because there’s so little [timber 

value] at stake.” These representatives noted that their level of scrutiny 

would likely be much higher if Good Neighbor projects were conducted in 

timber-rich areas. 

Page 35 GAO-09-277 Good Neighbor Authority 
 

Differences in the authorizing legislation for Colorado and Utah have led 

to differences in the types of projects conducted under Good Neighbor 

authority, which could lead to divergent outcomes if the authority is 

extended to other states. According to their Good Neighbor authorizing 

legislation, the U.S. Forest Service and BLM in Colorado may permit CSFS 

to perform watershed restoration activities on federal lands when the 

agency is carrying out similar and complementary activities on adjacent 

state or private lands. This has generally resulted in fuel reduction projects 

that take place near state or private boundaries, where nonfederal fuel 

reduction efforts had already occurred or were under way. In Utah, 

however, the authorization requires neither that the projects be part of a 

broader effort nor that they be adjacent to nonfederal lands. In practice, 

this less restrictive standard has led to a wider array of projects in Utah, 

such as the culvert replacement, barrier rock installation, and trail 

reconstruction undertaken in the Dixie National Forest. 

Moreover, to ensure the support of the public and environmental groups in 

Colorado, Utah, or other states, several stakeholders suggested that 

projects be undertaken only in the wildland-urban interface, where the 

potential public benefit is the greatest, rather than in more remote reaches 

of U.S. Forest Service and BLM lands. Also, according to federal and state 

officials as well as representatives of environmental groups, 

environmental stakeholders should be kept informed during Good 

Neighbor project design, and should be encouraged to participate during 

the NEPA process. Officials in Colorado and Utah told us they have done 

so on Good Neighbor projects to date, and they believe that this practice 

has been responsible for the general lack of opposition to Good Neighbor 

projects from members of the environmental community. 

Differences among states in the structure of their forest services, the value 

of their timber, and the potential content of their authorities, as well as the 

successes and challenges encountered in using Good Neighbor authority 

in Colorado and Utah, would be worth considering for agency officials 

contemplating future use of the authority—whether in Colorado, Utah, or 

other states. Although CSFS has prepared periodic summaries of Good 

Neighbor operations in Colorado, future users of the authority would 

benefit from a more systematic and comprehensive documentation of 

agencies’ experiences in conducting projects under Good Neighbor 

authority. While the agencies are not required to develop such 

documentation as part of their use of Good Neighbor authority, doing so 

could benefit future users—by, for example, providing them with an 

analysis of cost savings or other efficiencies and benefits that have been 

achieved through Good Neighbor’s use, and discussing the types of 

Page 36 GAO-09-277 Good Neighbor Authority 
 

projects in which the authority has been most successful. In addition, as 

they have done for stewardship contracting,24 the agencies could 

disseminate this information through agency Web sites and handbooks 

and incorporate it into existing training to ensure that future users have 

access to the information. Without such information, agency officials will 

need to independently assess which projects would best be conducted 

using the authority, and the extent to which individual projects might 

reduce costs or lead to other efficiencies and benefits. With the aid of this 

information, federal and state officials in Colorado and Utah, and 

potentially in other states, could consider adopting those procedures that 

have worked well and avoid the early pitfalls experienced in applications 

of Good Neighbor authority. 

Given the state of our nation’s forests, and in light of our nation’s longterm fiscal constraints, land management agencies are seeking to enhance 

their effectiveness in improving forest conditions and helping prevent 

severe wildland fires. Good Neighbor authority can help this effort by 

allowing federal and state agencies to work more closely together to treat 

lands across ownership boundaries. The agencies have differed on how 

best to apply the authority, however, as evidenced by the variation in its 

use to date. In Colorado, Good Neighbor authority has been used by 

federal and state partners to work across multiple ownerships to increase 

the effectiveness of fuel reduction efforts, while projects in Utah have 

focused on watershed health and rehabilitation of burned areas on U.S. 

Forest Service land. These variations arise in part because of differences 

in the laws authorizing these states’ activities, and in part because of 

differences in how state and federal agencies collaborate on Good 

Neighbor projects—highlighting an important issue as projects proceed in 

Colorado and Utah, and as Congress and the agencies consider expanding 

the use of Good Neighbor authority. That is, the type of projects 

conducted under the authority, and the extent to which those projects 

enhance the effectiveness of agency land management efforts, depend on 

many state-specific factors, including the scope of the Good Neighbor 

authority under which the state operates, the laws governing the state’s 

contracting activities, and the characteristics of federal land targeted for 

treatment, particularly the value of any timber. Without procedures that 

ensure timber accountability in all states, however, and without 

understanding and benefiting from the lessons learned from past use of 

Conclusions 

 

24GAO-09-23. 

Page 37 GAO-09-277 Good Neighbor Authority 
 

the authority, including the state-specific factors that influence the success 

of Good Neighbor projects, the agencies may fail to capitalize fully on the 

potential of Good Neighbor authority. 

We are making two recommendations to enhance the agencies’ use of 

Good Neighbor authority in Colorado and Utah as well as in states in 

which Good Neighbor projects may be authorized in the future. 

First, if U.S. Forest Service officials in Utah or BLM officials in Colorado 

decide to conduct timber sales under Good Neighbor authority, or if 

timber sales are pursued under expanded Good Neighbor authority in 

additional states, we recommend that the Secretaries of Agriculture and 

the Interior direct the agencies to first develop written procedures for 

Good Neighbor timber sales in collaboration with each state to better 

ensure accountability for federal timber. In doing so, the agencies may 

want to consult the U.S. Forest Service’s Good Neighbor timber sale 

procedures for Colorado. 

Second, we recommend that the Secretaries of Agriculture and the Interior 

direct the U.S. Forest Service and BLM, in collaboration with their state 

Good Neighbor partners, to document how prior experiences with Good 

Neighbor projects offer ways to enhance the use of the authority in the 

future and make such information available to current and prospective 

users of the authority. Specifically, the U.S. Forest Service should 

collaborate with Colorado and Utah, and BLM should collaborate with 

Colorado, to document information such as (1) the types of projects that 

have proven to be successful uses of the authority; (2) how differences in 

the authority’s scope within each state have affected project selection; 

(3) how project planning and implementation responsibilities have been 

divided among federal and state project partners; and (4) the costs and 

benefits associated with using Good Neighbor authority to conduct 

projects, including any project efficiencies and cost savings that have 

resulted from the authority’s use. In addition, to ensure that this 

information is available to current and future users of the authority, the 

agencies should develop a strategic approach for disseminating it—for 

example, through agency Web sites, handbooks, training, or other means. 

We provided the U.S. Department of Agriculture’s Forest Service, the 

Department of the Interior, CSFS, and UDFFSL with a draft of this report 

for review and comment. All four agencies generally agreed with the 

findings and recommendations in the report. The U.S. Forest Service 

Recommendations for 

Executive Action 

Agency Comments 

and Our Evaluation 

Page 38 GAO-09-277 Good Neighbor Authority 
 

noted, however, that it will address our recommendation about 

documenting experiences with Good Neighbor projects by providing our 

report to current and prospective users of the authority. While we are 

pleased that the U.S. Forest Service believes our report accurately 

documents lessons learned to date, we believe the agency will need to 

provide additional details if future users are to fully benefit from this 

information. For example, while our report includes a general description 

of the primary reasons for choosing Good Neighbor authority to conduct 

certain projects, it does not include a detailed discussion of the potential 

costs and benefits associated with this decision, which may prove 

beneficial to managers as they assess the applicability of the authority to 

future projects. The U.S. Forest Service’s written comments, along with 

our response, are presented in appendix II, Interior’s written comments 

are presented in appendix III, CSFS’s written comments are presented in 

appendix IV, and UDFFSL’s written comments are presented in appendix 

V. 

As agreed with your office, unless you publicly announce the contents of 

this report earlier, we plan no further distribution until 30 days from the 

report date. At that time, we will send copies to interested congressional 

committees, the Secretary of Agriculture, the Secretary of the Interior, the 

Chief of the Forest Service, the Director of the Bureau of Land 

Management, and other interested parties. The report also will be available 

at no charge on the GAO 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 or nazzaror@gao.gov. Contact points for our Offices of 

Congressional Relations and Public Affairs may be found on the last page 

of this report. GAO staff who made major contributions to this report are 

listed in appendix VI. 

Sincerely yours, 

Robin M. Nazzaro

Director, Natural Resources and Environment 

Page 39 GAO-09-277 Good Neighbor Authority 
Appendix I: Objectives, Scope, and 

Methodology 

Page 40 GAO-09-277 

Appendix I: Objectives, Scope, and 

Methodology 

Our objectives were to determine (1) the activities conducted under Good 

Neighbor authority, including the number, type, and scope of projects 

undertaken; (2) the federal and state guidance, procedures, and controls 

being used to conduct Good Neighbor projects, including contracting 

requirements and timber sale procedures; and (3) the successes, 

challenges, or lessons learned, if any, that have resulted from the use of 

Good Neighbor authority. Our review of Good Neighbor authority included 

obtaining documentation and holding meetings and discussions with the 

U.S. Department of Agriculture’s Forest Service and the Bureau of Land 

Management (BLM), the two agencies that have implemented Good 

Neighbor authority; the Colorado State Forest Service (CSFS) and the 

Utah Division of Forestry, Fire and State Lands (UDFFSL), the two state 

agencies that have conducted Good Neighbor projects; and Colorado State 

University (CSU) and the Utah Division of Purchasing, the agencies in 

each of these states generally responsible for administering service 

contracts for each state’s forest service. 

To determine the activities conducted under Good Neighbor authority in 

Colorado and Utah, we interviewed U.S. Forest Service, BLM, CSFS, and 

UDFFSL officials on their overall management of Good Neighbor projects, 

including how projects are chosen, the coordination involved between 

federal and state agencies, and the type and scope of projects that are 

undertaken. We also reviewed and analyzed specific data on Good 

Neighbor projects conducted through fiscal year 2008 that were provided 

by these officials, including the specific project objectives, location, start 

and completion dates, acreage involved, the federal cost share of the 

project, and the type of contract used in conducting the project—service 

or timber sale—as well as the amount and value of any timber removed 

from federal land. We also visited several completed or ongoing Good 

Neighbor project sites located on both U.S. Forest Service land and BLM 

land, including six sites in Colorado and four in Utah, to obtain an 

understanding of the type of work performed and type of equipment 

required to conduct projects. During our site visits, we also reviewed 

selected Good Neighbor projects’ contracting and financial files to obtain 

information on the planning, contracting, and monitoring processes each 

agency uses on Good Neighbor projects. We also obtained, through 

telephone interviews and e-mail, additional project information from U.S. 

Forest Service and state districts that we did not visit. We assessed the 

reliability of the project data we obtained by comparing a random sample 

of data provided to us by agency and state officials with similar 

information we had obtained directly from project files. We further 

assessed the reliability of timber sales data we obtained from the U.S. 

Forest Service’s timber sale accounting system by conducting telephone 

Good Neighbor Authority 
Appendix I: Objectives, Scope, and 

Methodology 

interviews with a U.S. Forest Service official responsible for entering data 

into the system, maintaining these data, and preparing reports using 

system data. In addition, GAO has previously assessed the reliability of 

data maintained in this system.1

 To ensure that GAO’s previous assessment 

was still accurate, we confirmed with the U.S. Forest Service that the 

information previously obtained on the reliability of the system remained 

relevant. As a result, we believe that the data we obtained from this system 

were sufficiently reliable for our purposes in conducting this review. 

To determine the federal and state guidance, procedures, and controls 

used to conduct projects under Good Neighbor authority, including state 

contracting requirements and timber sale procedures, we obtained 

documentation on Colorado’s and Utah’s procurement and contracting 

processes for acquiring services from vendors, including the requirements 

of each state concerning three fundamental principles of government 

contracting—transparency, competition, and oversight. Specifically, we 

chose several of the states’ procurement rules related to these three areas 

to examine, and we interviewed procurement and contracting officials 

with CSU and the Utah Division of Purchasing to obtain additional 

information on how the states put these rules into practice when 

conducting Good Neighbor projects. We also compared these selected 

state procurement and contracting requirements with those in the Federal 

Acquisition Regulation, and with U.S. Forest Service and BLM 

procurement guidance, to identify similarities and differences. To identify 

the timber sale procedures being used in Good Neighbor projects, we 

interviewed U.S. Forest Service, BLM, CSFS, and UDFFSL officials to 

determine whether Good Neighbor timber sale operating procedures had 

been established and their composition. We reviewed joint guidance 

prepared by the U.S. Forest Service and CSFS on conducting Good 

Neighbor projects to determine the type and extent of requirements 

incorporated. We also compared federal and state timber sale contracts 

and interviewed timber sale officials with the U.S. Forest Service in 

Colorado to obtain their opinions on differences between the two types of 

contracts, as well as any resulting effects on federal timber sale 

accountability. 

 

1

GAO, Federal Timber Sales: Forest Service Could Improve Efficiency of Field-Level 

Timber Sales Management by Maintaining More Detailed Data, GAO-07-764 (Washington, 

D.C.: June 27, 2007). 

Page 41 GAO-09-277 Good Neighbor Authority 
Appendix I: Objectives, Scope, and 

Methodology 

Finally, to identify successes, challenges, and lessons learned that the 

federal and state agencies experienced using Good Neighbor authority, we 

interviewed U.S. Forest Service, BLM, CSFS, and UDFFSL officials who 

had participated in Good Neighbor projects to obtain their views on the 

successes and challenges associated with the authority, including the 

factors they believe contributed to these successes and challenges and the 

measures they believe could be taken in the future to overcome these 

challenges. For example, we interviewed officials from five U.S. Forest 

Service ranger districts as well as officials from five CSFS district offices 

who had participated in Good Neighbor projects. We also obtained 

opinions about Good Neighbor authority from several state officials who 

had not participated in Good Neighbor projects, as well as their reasons 

for not participating. To obtain information on the potential uses of Good 

Neighbor authority in other states, we asked federal and state officials 

familiar with Good Neighbor authority, as well as representatives from the 

National Association of State Foresters, to identify states they believed 

would be the best candidates for us to interview regarding potential use of 

the authority. From the states that they recommended, we selected Idaho, 

Oregon, and Wyoming. We then interviewed officials in those states to 

discuss their opinions on whether Good Neighbor authority would be 

successful in their states, the factors for success, and any concerns that 

they believed would need to be addressed. We also spoke with other 

interested parties, including representatives of six environmental groups—

based in Colorado, Utah, and other western states—and two industry 

groups—one based in Washington, D.C., and the other based in South 

Dakota—to get their opinions on how well Good Neighbor authority was 

being implemented in Colorado and Utah, and the factors that would be 

important for success if Congress were to expand the authority to other 

states. 

We conducted this performance audit from June 2008 through February 

2009 in accordance with generally accepted government auditing 

standards. Those standards require that we plan and perform the audit to 

obtain sufficient, appropriate evidence to provide a reasonable basis for 

our findings and conclusions based on our audit objectives. We believe 

that the evidence obtained provides a reasonable basis for our findings 

and conclusions based on our audit objectives. 

Page 42 GAO-09-277 Good Neighbor Authority 
Appendix II: Comments from the U.S. Appendix II: Comments from the U.S. Department of Agriculture’s Forest Service 

Department of Agriculture’s Forest Service 

Note: GAO comment 

supplementing those in 

the report text appears at 

the end of this appendix. 

See comment 1. 

Page 43 GAO-09-277 Good Neighbor Authority 
Appendix II: Comments from the U.S. 

Department of Agriculture’s Forest Service 

Following is GAO’s comment on the U.S. Department of Agriculture’s 

Forest Service letter dated February 13, 2009. 

1. The U.S. Forest Service noted in its comments that it will address our 

recommendation about documenting experiences with Good Neighbor 

projects by providing our report to current and prospective users of 

the authority. While we are pleased that the U.S. Forest Service 

believes our report accurately documents lessons learned to date, we 

believe the agency will need to provide additional details if future 

users are to fully benefit from this information. For example, while our 

report includes a general description of the primary reasons for 

choosing Good Neighbor authority to conduct certain projects, it does 

not include a detailed discussion of the potential costs and benefits 

associated with this decision, which may prove beneficial to managers 

as they assess the applicability of the authority to future projects. As a 

result, we continue to believe it will be important for the U.S. Forest 

Service to systematically collect and document information on its 

experiences using Good Neighbor authority, and that this information 

should go beyond that contained in our report. 

GAO Comment 

Page 44 GAO-09-277 Good Neighbor Authority 
Appendix III: Comments from the Department Appendix III: Comments from the of the Interior 

Department of the Interior 

Page 45 GAO-09-277 Good Neighbor Authority 
Appendix IV: Comments from the Colorado Appendix IV: Comments from the Colorado State Forest Service 

State Forest Service 

Page 46 GAO-09-277 Good Neighbor Authority 
Appendix V: Comments from the Utah Appendix V: Comments from the Utah Division of Forestry, Fire and State Lands 

Division of Forestry, Fire and State Lands 

Page 47 GAO-09-277 Good Neighbor Authority 
Appendix VI: 

A

GAO Contact and Staff 

cknowledgments 

Page 48 GAO-09-277 

Appendix VI: GAO Contact and Staff 

Acknowledgments 

Robin M. Nazzaro, (202) 512-3841 or nazzaror@gao.gov

In addition to the individual named above, Steve Gaty, Assistant Director; 

David Brown; and Greg Carroll made key contributions to this report. 

Cindy Gilbert, Rich Johnson, Alison O’Neill, Jena Sinkfield, and Bill Woods 

also made important contributions to this report. 

Good Neighbor Authority 

GAO Contact 

Staff 

Acknowledgments 

(360964) 
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