Valles Caldera: The Trust Has Made Progress but Faces Significant Challenges to Achieve Goals of the Preservation Act
Published: 2009-10-30T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: In creating the Valles Caldera National Preserve from a unique parcel of land in north-central New Mexico, and by creating the Valles Caldera Trust as a wholly owned government corporation to manage the preserve, the Valles Caldera Preservation Act of 2000 established a 20-year public-private experiment to operate the preserve without continued federal funding. The Trust is charged with achieving a number of goals, including becoming financially self-sustaining by the end of fiscal year 2015. This report, GAO's second and last mandated by the Preservation Act, examines (1) the Trust's progress since 2000; (2) the extent to which the Trust has fulfilled certain of its obligations as a government corporation; and (3) the challenges the Trust faces to achieve the Preservation Act's goals. GAO analyzed documents, financial records, and other Trust information and interviewed current and former members of the Trust's Board and staff, as well as representatives of local interest groups and stakeholders.
section_title: What GAO Found
paragraphs: The Trust has taken steps to establish and implement a number of programs and activities to achieve the goals of the Preservation Act. It has rehabilitated roads, buildings, fences, and other infrastructure; created a science program; experimented with a variety of grazing options; taken steps to manage its forests; expanded recreational opportunities; and taken its first steps toward becoming financially self-sustaining. Nevertheless, it is at least 5 years behind the schedule it set for itself in 2004. According to Trust officials, a number of factors--including high turnover among Board members and key staff and cultural and natural resources and infrastructure that were not as healthy or robust as originally believed--have delayed its progress. Through fiscal year 2009, the Trust had yet to develop and put in place several key elements of an effective management control program for a government corporation. Specifically, the Trust lacked a strategic plan and annual performance plans, and it had not systematically monitored or reported on its progress--elements called for by the Government Performance and Results Act and recommended by GAO in its first report in 2005. The Trust's financial management has also been weak. Consequently, it has been difficult for Congress and the public to understand the Trust's goals and objectives, annual plans and performance, or progress. According to current Trust officials, becoming financially self-sustaining, particularly by the end of fiscal year 2015 when federal appropriations are due to expire, is the Trust's biggest challenge. Most of the Trust's other challenges follow from this one, including identifying, developing, or expanding revenue-generating activities that would enable the Trust to raise sufficient funds; obtaining funds for major capital investments; and addressing a number of legal constraints--such as its authority to enter into long-term leases or acquire property--which potentially limit its ability to attract long-term businesses that could generate revenues. Nevertheless, the Trust is continuing to explore opportunities for becoming financially self-sustaining.

section_title: Letter
paragraphs: In 2000, the Valles Caldera Trust was created by Congress as a 20-year  public-private land management experiment, whose aim was to protect  and preserve—without the need for continuing infusions of federal tax  dollars—a unique volcanic parcel of land in New Mexico. Today, however,  nearly halfway through the Trust’s 20-year life span, supporters and critics  disagree over whether this public-private model can succeed or should be  terminated.
The Valles Caldera Preservation Act of 2000 authorized the federal  government to purchase Valles Caldera, comprising about 89,000 acres of  privately owned land known as the Baca Ranch. The Caldera has served as  a model for geological studies of this area and other volcanic areas around  the world, and it has had religious significance for Native Americans since  prehistoric times. In addition, the landscape offers opportunities for  winter and summer recreation and provides ranchers with forage for  livestock. To manage the land, for which the government paid close to  $97 million, the Preservation Act also established the Trust, governed by a  Board of Trustees, as a wholly owned government corporation. The act  specifically charges the Trust with managing the land to achieve a number  of goals, including the following:    protecting and preserving Valles Caldera’s scientific, scenic, historic, and  natural values and archaeological, geological, and cultural resources for  future generations;   providing opportunities for public recreation;    providing for sustained-yield management of the ranch for timber  production and domesticated livestock grazing, insofar as these activities  are consistent with the Trust’s other responsibilities; and    becoming financially self-sustaining—that is, operating without federal  funds—within 15 years of the law’s enactment, or by the end of 2015.
In managing the preserve, the Trust is expected to incorporate elements of  both public and private administration to promote the preserve’s long-term  sustainability. The Trust is subject to the Government Corporation Control  Act (GCCA) and to the Government Performance and Results Act of 1993  (GPRA). These two laws provide general authorities for wholly owned  government corporations to carry out government functions and a general  management framework to enhance the federal government’s efficiency  and effectiveness and provide greater accountability for results,  respectively. Among other requirements under GCCA, the Trust must  obtain independent financial audits and report annually to Congress.  Under GPRA, the Trust must prepare a strategic plan with long-term  measurable goals and objectives and an annual performance plan for  achieving the strategic plan’s goals and objectives, and it must submit  annual performance reports to Congress and the President.
From the land’s acquisition in 2000 through fiscal year 2009, the Trust  received about $31 million in federal funding to operate and maintain the  land as a national preserve. Under the Preservation Act, the authorization  of appropriations for the Trust expires at the end of fiscal year 2015. If at  the end of fiscal year 2014, the Board believes that the Trust has met the  goals and objectives of the act but has not become financially self- sustaining, the Board may submit to the relevant congressional  committees a recommendation to authorize appropriations beyond 2015.  Also, under the act, the Trust itself is to terminate in fiscal year 2020.  According to the Preservation Act, in 2018 the Board must make a  recommendation to the Secretary of Agriculture whether to extend or  terminate the Trust in 2020. Within 120 days after receipt of the  recommendation, the Secretary must submit to Congress the Board’s  recommendation on extension or termination, along with the Secretary’s  recommendation. If the Trust is terminated, the preserve will become part  of the Santa Fe National Forest and therefore be managed by the U.S.  Forest Service, within the Department of Agriculture, as part of the  national forest system.
The Preservation Act also directs us to study and report twice on the  Trust’s activities, including on the Trust’s ability to meet its obligations  under the act. In November 2005, we issued our first report, which  concluded that the Trust had made some progress in meeting goals of the  act and recommended that it establish a more effective management  control program and increase its accountability to Congress and other  stakeholders. The present report, our second and last one required by the  Preservation Act, examines (1) the Trust’s progress since 2000; (2) the  extent to which the Trust has fulfilled certain of its obligations as a  government corporation; and (3) the challenges the Trust faces as it  continues moving toward fulfilling the goals of the act.
To address these issues, we analyzed documents, financial records, and  other information from the Trust and Forest Service, and we visited the  preserve to observe the actions the Trust has taken to date toward meeting  its statutory obligations. In addition, we analyzed and assessed the Trust’s  fulfillment of GCCA’s and GPRA’s requirements. We also interviewed  current and former officials of the Trust’s Board and staff, as well as  Forest Service officials, about the programs and activities that the Trust  has initiated since assuming management of the preserve. We interviewed  representatives of various local interest groups and stakeholders, such as  Los Amigos de Valles Caldera and Caldera Action. We also assessed data  related to revenue-generating programs and activities, such as the number  of livestock grazing on the preserve from year to year, and determined that  these data were sufficiently reliable for the purposes of this report. We  conducted this performance audit from November 2008 through October  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.
subsections: section_title: Background
paragraphs: About 1.2 million years ago, a volcano erupted and collapsed inward,  forming the crater now known as Valles Caldera, in north-central New  Mexico (see fig. 1). Almost entirely surrounded by the Forest Service’s  Santa Fe National Forest and the National Park Service’s Bandelier  National Monument, this geologically and ecologically unique area covers  about 89,000 acres of meadows, forests, hot springs, volcanic domes, and  streams supporting elk herds, fish, and other wildlife. While in private  hands, the Baca Ranch was operated as a working ranch, providing grazing  for livestock plus hunting and fishing for a limited number of visitors.  According to the Preservation Act, the working ranch arrangement was to  continue after ownership was assumed by the federal government.
The act also calls for the Trust to protect and preserve the land while  attempting to achieve a financially self-sustaining operation. “Financially  self-sustaining,” as defined by the act, means that management and  operating expenditures—including trustees’ expenses; salaries and  benefits; administrative, maintenance, and operating costs; and facilities  improvements—are to equal or be less than proceeds derived from fees  and other receipts for resource use and development. Appropriated funds  are not to be considered. To carry out its duties, the Trust has the  authority to solicit and accept donations of funds, property, supplies, or  services from any private or public entity; negotiate and enter into  agreements, leases, contracts, and other arrangements with any individual  or federal or private entity; and consult with Indian tribes and pueblos.
The Trust’s Board consists of nine trustees. The President of the United  States appoints seven of these trustees, and the other two are the  Supervisor of Santa Fe National Forest and the Superintendent of  Bandelier National Monument, under the jurisdiction of the Department of  the Interior’s National Park Service. Of the seven presidential appointees,  who are selected in consultation with New Mexico’s congressional  delegation, five must be New Mexico residents. Appointees are to be  selected on the basis of their expertise or experience, as follows: one  trustee each (1) with livestock and range management expertise; (2) with  expertise in recreation management; (3) who is knowledgeable in  sustainable management of forest lands for commodity and  noncommodity purposes; (4) with expertise in financial management,  budget and program analysis, and small business operations; (5) who is  familiar with the cultural and natural history of the region; (6) who is  active in a nonprofit conservation organization concerned with Forest  Service activities; and (7) who is active in state or local government  activities in New Mexico, with expertise in the customs of the local area.  Trustees are appointed to 4-year terms and can be reappointed; no trustee,  however, may serve more than 8 consecutive years. The trustees select a  chairman from the Board’s ranks. With the exception of the Board Chair,  trustees serve without pay, although they are reimbursed for travel and  subsistence expenses while performing their duties. The Board must hold  at least three public meetings a year in New Mexico. An executive director,  who is hired by the Board, oversees the Trust’s day-to-day operations.
section_title: The Trust Has Taken Steps to Achieve the Preservation Act’s Goals but Has Made Less Progress Than Expected
paragraphs: Although the Trust has taken steps to establish and implement a number  of programs and activities to achieve the goals of the Preservation Act, it is  behind the schedule it set for itself in 2004. A number of factors, such as  high turnover among Board members and key management staff, have  contributed to this slow progress, according to former and current Board  members and staff.
subsections: section_title: The Trust Took a Number of Steps toward Achieving Preservation Act Goals
paragraphs: As we reported in 2005, the Board’s first steps were to establish a basic  organization and to acquaint itself with conditions at the preserve. In  2001, the Board held regular meetings and listening sessions with the  public and gathered views on how the preserve should be managed. The  Board hired its first employee, an executive director, in October 2001 and,  in December 2001, issued 10 principles to guide future decision making.  These principles focused on a long-term view, emphasizing the ideas of  landscape protection, sound business management and good-neighbor  relations, the role of science in defining programs, and the quality of  experiences to be provided to the public at the preserve. Overall, these  principles constituted the Trust’s initial philosophy and foundation for the  programs and activities that the Trust undertook to fulfill the Preservation  Act’s goals. The following sections describe some of the Trust’s  accomplishments.
subsections: section_title: The Trust Has Surveyed and Repaired Roads, Buildings, Fences, and Other Infrastructure
paragraphs: Shortly after the federal government assumed ownership of the preserve,  the Trust learned that the existing infrastructure—such as roads,  buildings, fences, and water treatment facilities—was in disrepair and  needed rehabilitation. All the roads needed upgrading, fences were falling  down, rodents had invaded all the structures, and the water supply system  was not functioning. Work began immediately, and it continues today.
The preserve has about 1,000 miles of roads, including 140 miles of main  access roads. Road building into the preserve began in 1935, and by the  1970s, more than 800 miles of logging roads had been bulldozed into high- elevation forests, causing erosion and damaging downhill streams and  wetland areas (see fig. 2). On assuming its management role, the Trust  determined that the existing roads could not be readily used to support  administration, ranching, recreation, or other needs. Since then, the Trust  has upgraded over 14 miles of road to all-weather gravel standards, so they  are usable for passenger vehicles and are not as environmentally  damaging. To enhance safety and public viewing of the preserve, the Trust  also installed kiosks, scenic turnouts, and a new gate (see fig. 3); in  addition, it reconfigured the entry to and exit from New Mexico  Highway 4, the main access road to the preserve. The Trust has  systematically numbered and mapped a network of about 184 miles of  roads, which provide open public access, as well as restricted access for  the Trust’s land management activities.
At the time of the federal government’s purchase, the preserve had  numerous existing buildings, fences, and other structures. In 2002, the  Trust recognized that the majority of its structures needed major  restoration to bring them up to local building codes. Over the next 6 years,  the Trust conducted minor maintenance on the ranch buildings used to  house employees and documented the condition of structures of historic  value throughout the preserve (see fig. 4). In addition, the Trust repaired  the preserve’s 54 miles of boundary fences—including adjusting their  height to allow for elk movement—and installed signs restricting access to  the preserve. The Trust also assessed the layout and condition of 64 miles  of interior fences, many of which were used to separate pastures for  livestock. Other facilities, such as livestock corrals, have also been  assessed and rehabilitated, and in 2009 a new temporary visitor building  was purchased and placed on site (see fig. 5).
Regarding water supplies, when the federal government acquired the  preserve, the existing water treatment facility was not functioning, so no  potable water was available. Rehabilitating this facility became one of the  Trust’s top priorities. Repairs to the water collection and filtration systems  were completed in 2004, the water distribution system was repaired in  2005, and potable water became available in spring 2006. Still, the present  water supply freezes during the winter and can dry up during the summer;  the Trust is therefore evaluating groundwater reserves and options for  drilling a well to supply water year-round.
In the end, rehabilitating deteriorating infrastructure has proven to be an  expensive and time-consuming endeavor, and the Trust’s efforts have not  begun to address capital improvements, such as permanent visitor  facilities or roads in support of the Preservation Act’s goals. Indeed, as of  2008, the Trust still faced nearly $1.2 million in deferred maintenance costs  for existing buildings alone.
section_title: The Trust Created a Science Program to Lay the Foundation for Activities Allowed at the Preserve
paragraphs: From the time it first articulated the principles by which it would manage  Valles Caldera, the Trust viewed science as key to protecting and  preserving the land while developing programs that could bring in  revenue. It committed to using science in an “adaptive management”  framework, by continuously gathering and applying site-specific scientific  knowledge. According to the Trust’s Framework and Strategic Guidance  for Comprehensive Management, the chief characteristic of the Trust’s  view of adaptive management is the monitoring of natural systems and the  human activities impinging on those systems, coupled with use of the  monitoring information to guide and, when needed, revise management  goals and activities. Thus, according to Trust documents, the Trust makes  land management decisions on the basis of scientific research and  monitoring, taking into account the public’s views and federal  environmental requirements.
The science program includes three components: inventorying natural  resources, monitoring environmental changes resulting from the Trust’s  programs, and conducting research that will help manage the preserve’s  resources. Up and running in 2003, this program assists the Trust in  complying with federal environmental requirements, including those of the  National Environmental Policy Act of 1969 (NEPA). By 2008, the Trust  had assessed or was assessing most of the preserve’s natural resources,  such as its forests, biodiversity, watershed and stream health, fish habitats,  ground water quality, and geology and soils. In inventories of cultural  resources, the Trust has also uncovered over 430 historic and  archaeological sites. Such inventories will continue to be done as needed  before construction projects or other ground disturbance to comply with  NEPA guidelines. In addition, to assess the effects of activities such as  grazing, recreation, or forest thinning, the Trust has established long-term  programs to monitor ecological conditions, including climate, stream  water quality, and plant and animal habitat and population dynamics.  Finally, in collaboration with universities, federal and state agencies, and  other research entities, the Trust has hosted a wide range of research  programs, ranging from a study of the ecological drivers of rodent-borne  diseases to earth-coring studies of past climate change. For example,  hydrological research funded by the National Science Foundation through  the University of Arizona is to provide information to aid in the day-to-day  management of the preserve and also contribute to the understanding of  hydrologic systems overall. This research should help scientists  understand how much precipitation the preserve’s lands absorb and  predict the amount of runoff into its streams and rivers. As more data  become available, scientists may be able to forecast the effect of  precipitation and drought on water quality and forage availability on the  preserve and to use the information to drive future management decisions  about livestock and recreation. Each year the Trust has generated between  $1 million and $2 million of externally funded research.
To further enhance and communicate the results of the science program,  the Trust in August 2009 leased a facility in the town of Jemez Springs,  20 miles west of the preserve’s main gate, as a new science and education  center adjacent to the Trust’s administrative headquarters. The facility is  to accommodate a laboratory, classrooms, offices, a dining hall, and  lodging for visitors participating in the center’s formal and informal  science education programs for all age groups.
section_title: Since 2002, the Trust Has Been Experimenting with a Variety of Approaches to Manage Grazing
paragraphs: Given that the Preservation Act requires keeping the preserve as a working  ranch, grazing has been a central activity since the Trust began. Over the  years, the grazing program’s objectives, scope, and size have changed  repeatedly, in response to annual scientific assessments of forage  availability, as well as shifting directives from the Board. In addition,  because the preserve is federal land, continued grazing requires  completion of a NEPA environmental assessment. The Trust’s ultimate  goal is to manage its livestock operations for multiple aims, including  revenue generation, local community benefit, research, and public  education.
To date, the Trust has experimented with a number of grazing programs,  beginning in 2002 with a small drought-relief program that allowed just  over 700 cow-calf pairs belonging to local ranchers to graze on preserve  pastures for 5 weeks. The Trust also hosted a “conservation stewardship”  program for local ranchers, allowing about 200 cattle in each of 2 years to  graze on preserve lands for about 4 months while the ranchers  implemented conservation measures on their own lands. In addition, the  Trust has conducted a breeding program for 3 years to benefit local  ranchers and has tested varied cattle management approaches in an  attempt to make the program profitable for the Trust. In 2006, because of  drought, the Trust switched its focus to research assessing the effects on  cattle forage of controlled burning of the grasslands; initial findings  suggested that such burning improved forage quality. Then in 2008, the  Trust attempted to make a profit from grazing, allowing nearly 2,000 head  of cattle to graze at the preserve over a 4-month period and generating  about $58,000 in gross revenues. Because the cattle were brought in from  Mexico and were sold in Texas, this effort drew local criticism. Moreover,  the sheer number of cattle created conflicts with fishing and other  recreational activities. In 2009, the program again took on a research  emphasis and aimed to benefit local communities.
section_title: The Trust Has Taken a Number of Steps to Manage Its Forests
paragraphs: The preserve’s lands encompass more than 60,000 forested acres. When  the Trust was first established, these forests were envisioned as a possible  source of revenue toward the Preservation Act’s purpose of providing for  the multiple use and sustained yield of the preserve’s renewable  resources. But the Trust’s forest inventory in 2006 revealed a lack of  marketable timber, partly because of intensive logging in the past. As a  result of this logging and past fire suppression, about half the preserve’s  forested acres contain dense vegetation that pose a very high risk of  wildland fire. To date, therefore, the Trust’s forest management efforts  have focused on restoring forest health, reducing the risk of large fires,  and protecting watersheds. These efforts have also included identifying  the most effective means of reducing hazardous fuels and a potential  market for the sale of wood products (poles, mulch, pellets), sometimes in  collaboration with local businesses.
section_title: The Trust Continues to Expand Recreational Opportunities
paragraphs: Beginning in 2002, the Trust granted the public limited access to the  preserve for recreation; in most cases, it has charged a fee for this access.  In the beginning, public recreation was confined to guided hikes or van  tours. Over the next several years, the Trust allowed varied summer and  winter activities, including:    Hunting. The Trust has worked with New Mexico’s Department of Game  and Fish to hold elk hunts since 2002. In 2008, the Trust added a spring  turkey hunt.
Fishing. In 2003, the Trust granted 1,785 people access to the preserve’s  two fishable streams, on a first-come, first-served basis. The Trust also  holds adult and youth fishing clinics. In 2009, it began allowing anglers to  drive their own vehicles to parking areas near assigned stream reaches,  instead of providing van transportation as in previous years.
Hiking. Visitors have been allowed to hike at the preserve since 2002, first  in guided hikes, then on their own. The Trust has increased the number  and mileage of available hiking trails, opening about 30 miles of trails to  hikers, including 5 miles requiring no fee.
Other recreational activities. The Trust has also offered horse-drawn  wagon rides, sleigh rides, van tours, snowshoeing, cross-country skiing,  stargazing lectures, horseback riding, marathon runs, mountain biking,  group tours and seminars, workshops, antler collection, and overnight  photographic and birding excursions.
In 2006, the Trust also hosted its first free open house, which drew more  than 1,400 cars and nearly 4,000 people. The Trust used this event to  inform the public about then-current programs and future opportunities  and to monitor the effects of so many visitors. Since 2008, the preserve has  been open 7 days a week from April through September for summer  recreation and events and fewer days the rest of the year to accommodate  hunting and winter activities.
section_title: The Trust Has Taken Its First Steps toward Becoming Financially Self-Sustaining
paragraphs: The Preservation Act’s findings and purposes section states, among other  things, that the Baca Ranch could serve as a model for sustainable land  development and use of timber, grazing, and recreation and that  management of the ranch through a trust would eventually allow the ranch  to become financially self-sustaining. Over its existence, the Trust  recognized it had no marketable timber, but it has experimented with a  number of grazing options and expanded recreational opportunities.  Collectively, from 2005 through 2008, the Trust’s grazing, recreation, and  other activities have generated, on average, about $733,000 in gross  revenues per year (see table 1). In comparison, from 2000 through 2009,  the Trust received nearly $31 million in federal funding—an average of  about $3.5 million per year over the time frame.
Faced with average gross revenues amounting to about 20 percent of  average federal funding, the Board of Trustees contracted with an  independent consulting firm in 2008 to develop a revenue enhancement  study aimed at realizing annual revenues of about $5 million. Made public  in April 2009, this document details various options for generating  revenues of this scale and bringing the Trust to financially self-sustaining  status by the end of fiscal year 2015. These options include high-end  elements such as a luxury lodge, as well as more modest elements such as  tent camps. The options could be mixed and matched to produce a plan  that the Trust could use as it decides how to further develop infrastructure  and public programs at the preserve. According to the Trust, many of the  options described in this document are to be incorporated into the  alternatives the Trust is evaluating in preparing the environmental  analyses called for by NEPA before it can provide for greater public access  and use of the preserve.
section_title: The Trust Is Behind Its Own Schedule to Achieve the Goals of the Act in 2015
paragraphs: The Trust has not met the timeline that it set for itself to meet the  Preservation Act’s goals, as outlined in a required report to Congress in  2004. The timeline called for achieving financially self-sustaining status in  three phases over 15 years, a schedule reiterated in the Trust’s 2005  Framework and Strategic Guidance.
Phase 1, institution building, was to take place from 2001 through 2005.
During this phase, the Trust was to develop the staff and tools needed to  manage the preserve as a wholly owned government corporation,  including accounting systems and support mechanisms for its science- based adaptive management approach. No new roads or facilities were to  be constructed during phase 1; rather, all public programs were to use  existing infrastructure and temporary buildings and would therefore not  require a full environmental assessment or environmental impact  statement under NEPA.
Phase 2, program development, was to take place from 2005 through 2010.
During phase 2, the Trust envisioned completing NEPA analyses for major  infrastructure projects and beginning construction for an array of  programs, such as an integrated road and trails system, an interpretive  center, and a science and education facility.
Phase 3, program refinement, was to unfold from 2010 through 2015.
During phase 3, the Trust planned to cultivate additional sources of funds  and streamline programs to permit decreasing reliance on federal  appropriations as revenue-generating programs expanded. It was believed  that the experience gained in the prior phases would enable the Trust to  increase revenues and decrease costs in time to be self-sustaining by the  end of fiscal year 2015.
As of September 2009, only the science and grazing programs at the  preserve have moved into phase 2 of the Trust’s envisioned timeline. The  Trust’s publication in 2003 of its own NEPA regulations and its adaptive  management framework marked the passage of the science program into  phase 2. With completion of a forage environmental assessment in January  2009, the grazing program moved into phase 2. For recreation and  associated infrastructure development to move into phase 2, a public use  and access plan including NEPA compliance—which is due in mid-2010— must be completed. For the Trust’s forest management program, too, a  NEPA analysis will have to be done to move into phase 2. Thus, at the  close of fiscal year 2009, the Trust continued to work mostly on phase 1 of  its programs and activities—at least 5 years behind its anticipated  schedule (see fig. 6).
section_title: A Number of Factors Have Delayed the Trust’s Progress
paragraphs: Current and previous Trust Board and staff members have all identified  certain factors as contributing most significantly to delays in the Trust’s  progress. Key among these factors is high turnover among Board  members. Under the Preservation Act, at least three Board positions are  up for appointment every 2 years. In addition, members may resign for  personal reasons before completing their term of appointment, and the  two ex officio Board members from the Forest Service and the Park  Service may change according to how they are assigned within their own  agencies. A time lag—ranging from 2 to 9 months—inevitably occurs  between the end of some members’ terms and the beginning of others’.  Thus, it can take months before a full Board is seated once again. New  members face a learning curve. The result of such frequent turnover has  led to delays in decision making, as well as false starts to programs. For  example, an environmental assessment that needed to be completed  before permanent livestock operations could be put in place was restarted  three times before it was finally completed in 2009, largely because of  Board turnover.
The Trust has also experienced high turnover among key management  staff. Within its first 7 years, nine people served as acting executive  director or executive director; the most recent executive director reported  for duty in January 2009. The chief administrative officer position also  turned over four times. In addition, the position of communications  manager—key to the Trust’s obligation to communicate and collaborate  with the public—remained vacant for 3 years, until 2009. Among the  Trust’s key management staff, only the preserve general manager, who is  responsible primarily for the preserve’s natural resources, infrastructure,  and recreational programs, and the preserve science and education  director, who is responsible for and has developed the science and  education programs, have been with the Trust since they were first hired,  in 2002 and 2003, respectively.
In addition, according to the Trust’s Board and staff, they discovered upon  assuming their responsibilities that the preserve’s cultural and natural  resources and infrastructure were not as healthy or robust as they had  expected or as described in the opening to the Preservation Act. For  example, road building and timber cutting in high-elevation forests had  been done since the early 1930s, and streamside and other areas had been  damaged by logging roads and overgrazing. Forests clear-cut in the 1960s  and 1970s had been replaced by dense stands of young trees that provide  little marketable timber and present a wildland fire hazard. Further, the  act directed the Trust to open the preserve for public recreation within  2 years after the federal government purchased the land. As a result, the  Trust found itself with more ecological restoration and infrastructure  rehabilitation to do than expected—even while providing public access to  the preserve—almost immediately after it assumed active management of  the land in August 2002.
Finally, almost everyone we interviewed observed that one or more of the  foregoing factors contributed to the Trust’s inability to focus on  establishing itself as a fully functioning government corporation, which in  turn exacerbated the effects of Board and staff turnover. Ultimately, these  shortcomings raised serious concerns among interest groups and the  public about whether the Trust could successfully manage the preserve in  the manner envisioned by the Preservation Act.
section_title: The Trust Has Failed to Put in Place Key Elements of an Effective Management Program
paragraphs: As of September 2009, the Trust had yet to develop and put in place  several key elements of an effective management control program for a  government corporation, as required under GPRA and as we  recommended in our previous report. Specifically, the Trust had not  clearly defined a long-term strategic plan, developed annual performance  plans, or systematically monitored and reported its progress. Additionally,  the Trust’s financial management has been weak. Consequently, it has  been difficult for Congress and the public to understand the Trust’s long- term goals and objectives, annual plans and performance, or progress.
subsections: section_title: As a Government Corporation, the Trust Is Required to Have Effective Management Controls
paragraphs: For government agencies and corporations, GPRA and GCCA specify the  means to achieve an effective management control program. That is, they  establish a framework for government entities to provide reasonable  assurance that an organization’s operations are effective and efficient, that  its financial reporting is reliable, and that the organization is complying  with applicable laws and regulations. This framework includes, among  other components, (1) a strategic plan with long-term, measurable goals  and objectives; (2) annual performance plans for achieving the strategic  plan’s goals and objectives; (3) performance monitoring and reporting; and  (4) annual management reviews and financial audits. Such plans, methods,  and procedures are collectively known as internal, or management,  controls.
Under GPRA, a federal agency is required to develop a strategic plan that  covers a period of at least 5 years, to be updated every 3 years, and  includes the agency’s mission statement, identifies its long-term strategic  goals and objectives, describes strategies to achieve those goals and  objectives, explains the relationship between long-term and annual goals,  analyzes key external factors, and specifies how and when program  evaluations will be conducted. GPRA further requires each agency to  submit an annual performance plan, which must establish performance  goals that link the goals of the agency’s strategic plan directly with  managers’ and employees’ day-to-day activities. In essence, this plan is to  set forth the yearly performance goals the agency will use to gauge  progress toward the strategic goals, identifies performance measures the  agency will use to assess its progress, explains the procedures the agency  will use to verify and validate its performance data, and ties these goals  and measures with the processes and resources the agency will use to  meet performance goals. In addition, GPRA requires agencies to report  each year, usually to the President and Congress, on program performance  for the previous fiscal year. This annual performance report should  describe the performance indicators established in the agency’s annual  performance plan and the actual program performance achieved  compared with the performance goals. It should also explain why a  performance goal has not been met and set forth plans for achieving it.  Finally, the plan should also summarize the year’s program evaluations  and findings. Key steps and critical practices for GPRA implementation  include involving stakeholders in defining missions, plans, and outcomes;  producing key results-oriented performance measures at each level of the  agency or organization; and using the results of measuring past  performance to inform future planning.
Under GCCA, a government corporation must submit annual management  reports to Congress, including statements of financial position, operations,  and cash flow; a budget report reconciliation; a report summarizing the  results of an annual financial audit; and other information about  operations and financial status. GCCA also requires that the corporation’s  financial statements be independently audited in accordance with  generally accepted government auditing standards.
Finally, under the Preservation Act, the Trust is required to report annually  to Congress on its activities. These reports are to be “comprehensive and  detailed report of  operations, activities, and  accomplishments for the prior year, including information on the status of  ecological, cultural, and financial resources . . . and benefits provided by  the Preserve to local communities” and “shall also include a section that  describes the Trust’s goals for the current year.” The law also requires  preparation of an annual budget.
section_title: The Trust Lacks a Strategic Plan
paragraphs: We reported in 2005 that the Trust lacked a GPRA-compliant strategic plan  and recommended that it develop such a plan. Although the Trust agreed  with our recommendation, it still did not have a plan in place as of  September 2009. The Trust has, however, produced two documents (one  of them in response to a previous recommendation from us) that offer  some strategic guidance, although neither of these meets GPRA  requirements or was used as a formal strategic plan. The first guidance  document was the 2005 Framework and Strategic Guidance for  Comprehensive Management, which presents the values and vision the  Trust was to apply in making management decisions. The document  articulates the Trust’s commitment to the various goals of the Preservation  Act, including operating the preserve as a working ranch according to  principles of science-based adaptive management, striving toward  financial self-sufficiency, and making the preserve accessible to visitors.  As we observed in our 2005 report, the 187-page document describes,  among other things, the preserve’s history and natural features; the Trust’s  approach to decision making; and public involvement at the preserve,  including a range of potential public uses, from hunting and fishing to  hiking and camping.
The mission of the Valles Caldera Trust is to operate the preserve as a working ranch; to  become financially self-sustaining; to meet the varied needs of visitors; to utilize and  steward the multiple resources of the preserve; and to work collaboratively with our  neighbors.
The document also outlines six goals—which the Trust labeled alternately  as “actions” or “near-term goals”—each accompanied by a desired  outcome, objectives, strategies or actions, and metrics. For example, one  of the six near-term goals is to evaluate existing facilities and identify  needs for additional infrastructure; eight strategies and actions are given  for achieving the objectives for that goal. The desired outcome is  “identification of essential infrastructure” to support operations and  “achievement of financial self-sustainability,” and one of the objectives is  to improve the entrance to the preserve and visitor service center. To  fulfill this objective, the document states that the Trust will engage a  contractor to design and improve the preserve’s entrance and gives as the  metric for measuring progress the completion of a new preserve entrance  during fiscal year 2007.
Both the 2005 and 2006 documents fall short of GPRA’s requirements for  effective strategic planning in a number of respects. For example, despite  its broad and philosophical articulation of the Trust’s guiding principles— essentially, the Trust’s vision and mission—the 2005 Framework and  Strategic Guidance does not meet GPRA’s requirements for a formal and  detailed strategic plan. Indeed, title aside, this document never claims to  be a formal strategic plan. In its own words, the document does “not  intend to present a blueprint for future management of the preserve” but  rather to sketch “the range of possible programs the Trust will consider  implementing in pursuit of  goals.”  Likewise, although the 2006 “Strategic Planning Document” combines  elements of strategic planning (mission statement, goals, and objectives)  with elements of annual performance plans (actions and metrics), it does  not cover a 5-year period, has not been updated, does not explain the  relationship between long-term and annual goals, does not analyze key  external factors, and does not specify how and when program evaluations  are to be conducted. Furthermore, according to Trust officials and senior  staff, the document was drafted and approved by the Trust’s Board  without benefit of guidance or assistance from stakeholders, such as  Congress and the public, as expected under GPRA; neither did the Board  specifically instruct the staff to implement the actions or monitor the  metrics. By failing to develop a strategic plan from the beginning of its  operation of the preserve in 2002, as well as failing to craft and adopt a  formal strategic plan later, the Trust lost an opportunity to move forward  systematically as an institution—independent of personnel turnover in  either the Board or staff—toward meeting the Preservation Act’s goals. In  September 2009, recognizing the value of better strategic planning, Trust  officials told us they were planning to work to develop a GPRA-compliant  plan with an outside consultant experienced in developing strategic plans  for federal agencies.
section_title: The Trust Has Not Fully Met the Requirements for Performance Planning, Monitoring, or Reporting
paragraphs: Since its beginning, the Trust has failed to fully meet GPRA’s annual  performance planning, monitoring, or reporting requirements. The Trust  has not put together formal annual performance plans containing either  specific performance goals for the next fiscal year—goals tied directly to  any strategic goals stated in the 2005 Framework and Strategic Guidance  or November 2006 strategic planning document—or any performance  measures or related information for monitoring its progress. Under GPRA,  an annual performance plan must establish yearly performance goals  linked to long-term goals of a strategic plan; identify performance  measures that will be used to gauge progress toward meeting long-term  strategic goals; explain the methods to be used for validating and verifying  performance data; and link the goals and measures with the processes and  resources, such as staffing and funding, that will be used to meet the  performance goals. The only documents that the Trust has produced to  date that begin to address these requirements are its 2006 strategic  planning document and fiscal year 2008 annual report to Congress. While  not labeled an annual performance plan, the 2006 strategic planning  document does identify “near-term” (performance) goals and metrics  (performance measures) for fiscal year 2007, as well as for fiscal years  2008 and 2009. These goals and metrics, however, are not linked to any  long-term strategic goal, as required by GPRA, nor does the planning  document meet other GPRA requirements for annual performance plans.  In addition, although the Trust’s fiscal year 2008 annual report to Congress  identifies goals for the upcoming 2009 fiscal year, along with metrics,  neither the goals nor the metrics are linked to any long-term strategic goal  or strategy for achieving such a goal. Neither are other requirements for  annual performance plans addressed in this annual report. Although the  Trust’s fiscal year 2007 annual report identifies 2008 performance goals,  without metrics, annual reports before 2007 do not identify either  performance goals or metrics for the next fiscal year.
In monitoring its performance, the Trust has not established or monitored  a stable set of quantitative indicators of progress over time. In its annual  reports to Congress, the Trust summarized the past year’s  accomplishments and mentioned its intentions for the future, sometimes  quantitatively but more often qualitatively. For example, an early two-page  report for fiscal year 2004 lists as one preserve goal to “manage public use,  access to and the occupancy of the preserve” and notes an  accomplishment under this goal as completing a road inventory of  76 miles. The Trust’s plan, as stated, was to use this inventory to develop a  transportation plan that was to begin in fiscal year 2007 and be completed  in fiscal year 2008; development of this plan was labeled very high priority.  But no methods or indicators for tracking the progress of this  transportation plan were given. Moreover, although the transportation  plan was supposed to begin in 2007 and be completed by 2008, reference  to the plan in the Trust’s 2007 annual report to Congress is essentially  identical to the wording in its 2006 annual report, and to date, no  transportation plan has been developed. Similarly, for the Preservation  Act’s goal of achieving financially self-sustaining operations, the Trust’s  plan as stated in its 2004 annual report says only that it will implement  financially sound business practices, develop and implement a business  plan incorporating an annual budget tied to a plan of work for 5 years, and  revise this business plan annually; again, the assigned priority is “very  high.” Nevertheless, our review of Trust documents found that progress  toward implementing these very high-priority plans was not formally  monitored, nor were the plans fully executed. In fact, the 2005 annual  report copies the wording of the 2004 report with respect to development  of a business plan, the 2006 annual report makes no mention of a business  plan, and the 2007 annual report lists developing a strategic business plan  as one of its goals for 2008.
Because it has not developed annual performance plans with performance  goals, the Trust has not produced formal annual performance reports as  required by GPRA. Since 2006, however, annual reports required by the  Preservation Act, as well as a 5-year State of the Preserve report released  in 2007, detail the Trust’s operations, activities, and prior year’s  accomplishments, including the status of the preserve’s natural, cultural,  and financial resources and benefits to local communities. While the  Trust’s annual reports before 2006 did not address all these elements, the  reports have improved over the years, becoming more detailed and  comprehensive. The most recent annual report, for fiscal year 2008,  contains major sections devoted to attainment of fiscal year 2008 goals;  Trust organization, program accomplishments, and budget; and goals for  fiscal year 2009. Each section on fiscal year 2008 goals attained (e.g.,  develop a strategic business plan)    states the goal’s objective (e.g., “to create a business plan that identifies  options to generate revenues from programs”);    gives the status of progress (e.g., the Trust awarded a contract to a  consulting firm to develop this business plan); and   offers a brief narrative related to the goal.
With respect to goals for 2009, the report states each goal along with a  statement of its objective, metric for measuring progress, and related  narrative. This annual report and previous ones do not, however, report on  the status of current year goals that were not attained or link back to a  long-term strategy.
The evolution of the Trust’s reports suggests a growing understanding  within the organization of the need for key management elements, such as  strategic goals, annual performance goals and plans, and measurable  performance indicators. Our review of the annual reports nevertheless  revealed a lack of consistency in report format, organization, and content  from year to year, particularly in relation to measurable indicators of  progress. For example, before 2007 the Trust counted and reported only  the number of paying visitors to the preserve. In 2007, however, it began to  include nonpaying visitors in visitor counts—a key change for  understanding the growth in Trust programs. Yet this change in data  collection was never explicitly pointed out in the 2007 annual report.  Furthermore, given the absence of links in any of these reports directly to  metrics listed in the Trust’s November 2006 strategic planning document,  it is difficult to follow the progress of one year’s “plan” through  subsequent years or to systematically track the Trust’s progress toward  accomplishing the Preservation Act’s overarching goals.
section_title: The Trust’s Financial Management Has Been Weak
paragraphs: Compounding the absence of systematic strategic planning and routine  performance planning, monitoring, and reporting, the Trust’s financial  management has suffered from varied and numerous weaknesses. From  when the Trust first took over management of the preserve through fiscal  year 2003, the Trust’s finances were administered by the Forest Service. At  the beginning of fiscal year 2004, the Trust briefly attempted to do its own  accounting in house. When this attempt failed, however, partly because of  turnover in accounting staff, it shifted these functions to the Department  of the Interior’s National Business Center, which provided accounting  services from fiscal year 2004 until fiscal year 2008. At the start of fiscal  year 2008, the Trust once again moved its accounting operations, to the  Forest Service’s Albuquerque Service Center, so as to bring its finances  under a single, integrated financial management system and to reduce  costs.
In part because of poor financial management and accounting practices,  inadequate records, and difficulties in hiring and retaining accounting  staff, until 2007 the Trust could not produce financial statements that  would have enabled it to fulfill its obligation to undergo an annual  independent audit, as required by GCCA. As we reported in 2005, the Trust  contracted in 2003 with an independent accounting firm for auditing  services, but the firm recommended that the audit be postponed because  the Trust lacked the financial policies, procedures, and records needed to  produce auditable financial statements. It took several years for the Trust  to reconstruct its financial transactions and prepare any auditable  statements. At the end of 2007, an independent auditing firm was  contracted. The firm completed its work in 2009, producing independent  auditor’s reports for fiscal years 2005 through 2008.
The auditor’s reports found numerous weaknesses in the Trust’s  accounting, management control, and compliance with applicable laws  and regulations. For example, the audit report for fiscal year 2008 found  “material weaknesses” and “significant deficiencies” ranging from a lack of  documented policies and procedures to the lack of a secure information  technology system and failure to properly process cash and check  payments. Consequently, according to the auditor’s report, decisions  made by the Trust on the basis of deficient information could themselves  be inaccurate or misleading. Moreover, because the Trust had not  identified such deficiencies, it could not and did not report them to  Congress. Among its other findings, this report also confirmed the lack of  performance goals and objectives in compliance with GPRA requirements.
The audit reports for all the audited fiscal years thus cast considerable  doubt on the accuracy and completeness of the Trust’s annual or other  reports to date and its degree of compliance with applicable laws.
As a result of the auditor’s reports, the Trust has made an effort to  improve its management control framework. In July 2009, for example, the  Trust asked the Albuquerque Service Center to conduct an “internal  control assessment” of the Trust’s operations, which the center had begun  to do as of the end of fiscal year 2009. Once completed, this assessment  could help improve the Trust’s management controls.
section_title: The Trust Sees Becoming a Self- Sustaining Entity as Its Greatest Challenge
paragraphs: In managing a remote, undeveloped expanse of public land under the  public-private experiment created by the Preservation Act, the Trust is  breaking new ground. In accordance with the act’s goals, the Trust is  responsible for preserving and protecting the preserve’s resources while  generating revenues from these resources. The long-term vision  articulated in the Preservation Act is for the Trust to become a self- sustaining entity, without need for federal funding. Yet the current Board  chairman and the Trust’s executive director believe that, of all the goals  for the foreseeable future, becoming financially self-sustaining is the most  challenging. A consensus among Board members is that the Trust will not  become financially self-sustaining by the end of fiscal year 2015 as  envisioned by the Preservation Act; a few within the Trust doubt that this  goal can ever be achieved. In particular, as for other multiple-use land  management agencies, a daunting corollary to the Trust’s mission is how  to balance managing the land to produce a sustained yield of revenue- generating resources with preserving and protecting those resources and  other natural and cultural values of the preserve. Others external to the  Trust, such as Los Amigos de Valles Caldera and Caldera Action, have  expressed similar views about the Trust’s ability to become financially  self-sustaining. Nevertheless, the Trust is continuing to explore  opportunities for becoming financially self-sustaining.
As of the end of fiscal year 2009—nearly halfway through the 20-year  public-private land management experiment and about 6 years before the  authorization for Trust appropriations expires—the Trust had only begun  to focus on the goal of becoming financially self-sustaining. A number of  issues—such as its remaining life expectancy, activities capable of  providing sufficient revenues, funds for needed key capital investments,  and legal issues—present significant challenges to achievement of this  goal. These challenges include the following:    Completing key steps to becoming financially self-sustaining in the time  remaining before the end of fiscal year 2015, when the current  authorization of appropriations expires. If the Trust is not well on its way  toward becoming financially self-sustaining by the end of fiscal year 2015,  the Trust may or may not have the funds to continue operating, regardless  of how much or how little progress it has made on its various land  management and recreation programs. Yet within the 6 years from the  beginning of fiscal year 2010 to the end of fiscal year 2015, the Trust must  develop a public use and access plan, including an environmental impact  statement and an associated transportation plan; secure funding to  implement these plans; begin and complete construction; and then begin  operating the programs to generate revenues. All these activities could  well take longer than 6 years.
Identifying, developing, or expanding revenue-generating activities that  would enable the Trust to raise sufficient funds to become financially self- sustaining. To date, several anticipated sources of revenue have not  materialized or have not materialized to the degree anticipated. For  example, the vision of timber production as a major source of revenue  disappeared when an inventory of the preserve’s timber resources  revealed that few to no trees of commercial value remained after clear- cutting in the mid-twentieth century. Both current and former Trust  officials noted that many of the forested areas are more a liability than an  asset to the Trust because they are covered with dense vegetation that  could fuel large wildland fires. Recreation, too, failed to prosper as  expected. The Trust had anticipated holding luxury elk hunts to provide a  major source of future revenue and, in 2008, sought state legislation to  allow these hunts. The proposal received public criticism, however, and  the legislation failed. In addition, the Trust’s several years of  experimenting with various approaches to grazing has led to the  realization that grazing will not make as much money as anticipated.
Obtaining funding for major capital investments to construct and  preserve facilities and other infrastructure needed to generate revenues.  The 2009 revenue enhancement study commissioned by the Trust  estimated that somewhere between $21 million and $53 million would be  needed to further develop the facilities and infrastructure to support  greater public use of the preserve, such as additional parking lots and  further road upgrades, a visitor center, an educational research center, and  a visitor lodge. Yet neither the revenues the Trust has generated to date  through any of its programs nor current appropriations are sufficient to  make such investments.
Legal constraints. The Trust faces several legal constraints that may affect  its ability to achieve financially self-sustaining operations, according to  Trust officials. Provisions of the Preservation Act—specifically, that the  Trust expires in 2020 and that it is prohibited from entering into leases  lasting longer than 10 years—limit the Trust’s ability to attract  concessionaires or other enterprises desiring to establish long-term  businesses on the preserve that could generate revenue for the Trust.  Another question facing the Trust, according to Trust officials, is what  authority it has to borrow and lend money. Trust officials said that  Agriculture’s General Counsel told them that the Preservation Act does not  specifically address this question. The Trust recently learned it has no  authority to borrow money from the Federal Financing Bank, whose  purpose is to make loans to government corporations. Trust officials also  raised concerns about the Trust’s authority to purchase property outside  the preserve or to construct new buildings inside the preserve. In addition,  the Trust has expressed concern about not having access to the federal  “judgment fund”—a permanent indefinite appropriation available to  federal agencies under certain circumstances to satisfy judgments against  them—to cover liability incidents such as hunting accidents. According to  a Senate committee report on a 2004 bill amending the Preservation Act,  the Department of Justice opposed a provision of the bill that would have  provided the Trust access to the judgment fund. The Trust is paying over  $80,000 annually for liability insurance.
section_title: Conclusions
paragraphs: Nine years have passed since the federal government purchased Valles  Caldera, and 11 years remain before the Valles Caldera Trust could, under  the Preservation Act, come under Forest Service jurisdiction if it fails to  become financially self-sustaining. The ultimate success of the Valles  Caldera land management experiment hinges on the Trust’s ability to  become a fully functioning, financially self-sustaining government  corporation while simultaneously preserving and protecting the land’s  natural, cultural, and recreational values. We acknowledge that achieving  such a mission is no easy task, and we recognize that the Trust continues  to work toward achieving these goals. Nevertheless, the Trust has  struggled for nearly a decade to establish the basic framework for  effective management required of government corporations, it has not  maintained the pace of progress it set for itself, and it faces a number of  legal constraints. Thus, it is uncertain whether the Trust can overcome its  management and legal challenges and, as many Board and management  officials of the Trust have also noted, whether it can achieve financially  self-sustaining status by the Preservation Act’s 2015 deadline. We believe  that our previous recommendations, if implemented, could substantially  enhance the Trust’s ability to make greater progress toward meeting the  goals of the act, as well as to improve management oversight,  accountability, and transparency under GCCA and GPRA. We therefore  reiterate the need for the Trust to fully implement recommendations from  our 2005 report, specifically, continue to develop—and systematically  implement—the following elements of effective management:    a formal strategic plan that includes measurable goals and objectives;    a plan, including planned timelines, for becoming financially self-   mechanisms for periodic monitoring and reporting of the Trust’s  performance to Congress and other stakeholders.
section_title: Recommendation for Executive Action
paragraphs: To help further the Trust’s efforts toward becoming a financially self- sustaining government corporation, we recommend that the Trust’s  Chairman of the Board and Executive Director work with the relevant  congressional committees to seek legislative remedies, as appropriate, for  the legal challenges confronting the Trust.
section_title: Agency Comments and Our Evaluation
paragraphs: We provided the Valles Caldera Board of Trustees with a draft of this  report for review and comment. The Board generally agreed with our  findings and conclusions but did not comment on our recommendation. In  its written comments, the Trust said it found our assessment of its  accomplishments to date accurate, although it provided additional details  about infrastructure, forestry work, the livestock program, and science  and education. In addition, the Board agreed with our finding that the  Trust has failed to put in place an effective management program, saying  “there is no excuse for these plans and controls to be lacking” and “top  priority will be given to reaching prompt compliance with the law.” The  Board also noted that we aptly described the current and future challenges  the Trust is facing and stated that financial self-sustainment by 2015 is not  a possibility under the current provisions of the Preservation Act. Without  agreeing or disagreeing with our recommendation that the Trust work  with Congress to seek legislative remedies for its legal challenges, the  Trust stated that changes to the law are needed.
We are sending copies of this report to the Board Chairman, Valles Caldera  Trust and other interested parties. In addition, the report will be available  at no charge on the GAO Web site at http://www.gao.gov.
If you or your staff members 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 II.
section_title: Appendix I: Comments from the Valles Caldera Trust
section_title: Appendix II: GAO Contact and Staff Acknowledgments
subsections: section_title: Staff Acknowledgments
paragraphs: In addition to the person named above, David P. Bixler, Assistant Director;  Lisa Brownson; Ellen W. Chu; Elizabeth Curda; Richard P. Johnson;  Mehrzad Nadji; James M. Rebbe; Dawn Shorey; Jena Sinkfield; and Maria  Vargas made key contributions to this report.