oversight

Public Lands: Limited Progress in Resource Management Planning

Published by the Government Accountability Office on 1990-09-27.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

                           PUBLIC LANDS
                           Limited Progress in
                           Resource Management
                           Planning




                                                                                 142564




                                                         RELEASED
                          RESTRICTED --Not      to be released outside the
                          General Accounting Office unless epedfically
                          approved by the OfTice of Congressional
                          Relations.

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GAO/M :EI)-!m-225
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                                                                             ---__----~~I   --
        united
          states
GA!!0   General Accounting  OfPice
        Washington, D.C. 20648

        Resources, Chnmunity,   and
        Economic Development    Division

        R-236947

        September 27,lQQO

        The Honorable Bruce F. Vento
        Chairman, Subcommittee on National
          Parks and Public Lands
        Committee on Interior and Insular Affairs
        House of Representatives

        Dear Mr. Chairman:

        This report responds to your request that we review the progress the Department of the
        Interior’s Bureau of Land Management is making in developing and implementing land-use
        plans and in designating areas of critical environmental concern.

        As arranged with your office, unless you publicly announce its contents earlier, we plan no
        further distribution of this report until 30 days from the date of this letter. At that time, we
        will send copies to the Secretary of the Interior and other interested parties. We will make
        copies available to others upon request.

        This report was prepared under the direction of James Duffus III, Director, Natural
        Resources Management Issues, (202) 276-7756. Other major contributors are listed in
        appendix II.

        Sincerely yours,




        J. Dexter Peach
        Assistant Comptroller General
Executive Summ~                                                                        ,


             The Department of the Interior’s Bureau of Land Management adminis-
Purpose      ters 270 million acres of federally owned lands. These areas, called the
             “public lands” contain many resources including minerals, timber,
             rangeland, fish and wildlife habitat, recreation areas, and cultural and
             historic sites.

             The Bureau prepares resource management plans to guide the manage-
             ment and use of these lands. The plans are important because they are
             the mechanism for resolving conflicts among the multiple uses of the
             lands, for ensuring that the lands can be used currently and are also
             being preserved for future generations, and for designating and pro-
             tecting areas of critical environmental concern (ACEC).

             The Chairman, Subcommittee on National Parks and Public Lands,
             House Committee on Interior and Insular Affairs, asked GAOto review
             (1) the Bureau’s progress in completing resource management plans, (2)
             whether the plans contain measurable goals and milestones, and (3) the
             Bureau’s progress in designating and protecting ACECS.


             Before passage of the Federal Land Policy and Management Act of 1976
Background   (FLPMA), the Bureau managed the public lands custodially, pending their
             transfer to other federal agencies, states, or private ownership. Under
             these circumstances, there was little need for comprehensive land-use
             plans. In 1976, however, FLPMAdramatically revised the federal govern-
             ment’s policy on the ownership and management of the public lands, by
             directing that they generally be retained in federal ownership and
             requiring that land-use plans (resource management plans) be developed
             and used to guide the management of the public lands.

             F’LPMAalso directed that the planning process give priority to the identi-
             fication, designation, and protection of ACES-areas where special man-
             agement is required to (1) protect and prevent irreparable damage to
             important historic, cultural, or scenic sites; fish and wildlife resources;
             or other natural systems or processes or (2) protect the public’s life and
             ensure its safety from natural hazards.

             The Bureau intends to prepare 136 resource management plans for the
             public lands. More than 99 percent of these lands are located in the 11
             contiguous states that include or are west of the Rocky Mountains and
             Alaska. For example, 69 percent of the total land area of Nevada is
             under the Bureau’s jurisdiction.



             Page 2                            GAO/RCED-90.226 Resource Management Planning
                           Executive Summaxy




                           Over 13 years after FLPMAwas enacted, the Bureau has completed less
Results in Brief           than half of the 136 resource management plans needed to guide the
                           management of the public lands. The Bureau estimates it will complete
                           all 136 plans by 1997.

                           The planned goals and decisions of those plans completed are of limited
                           practical value unless the Bureau converts the goals and decisions into
                           on-the-ground actions. GAOfound that the Bureau had made limited pro-
                           gress in implementing its completed plans. GAOfound that specific
                           details that are needed to implement plan goals and decisions typically
                           had not been developed, scheduled, tracked, or linked to the budgetary
                           resources necessary to carry them out. In July 1990, the Bureau issued
                           instructions to its field offices that, if properly implemented, should
                           address the scheduling, tracking, and budget linkage problems identified
                           by GAO.Because of the importance of a scheduling, tracking, and budget
                           linkage system to convert plan goals and decisions into on-the-ground
                           actions, GAObelieves that the Bureau needs to closely monitor its field
                           offices’ implementation of its July 1990 instructions.

                           Although F+LPMAdirected that the Bureau give priority to designating
                           and protecting ACECS,GAOfound that the Bureau has given its field
                           office managers broad discretion in making decisions on these areas. In
                           turn, Bureau field office managers have used this broad discretion in
                           conjunction with their own philosophical views to make inconsistent
                           .&EC designation decisions. In fact, ACECSwere not even singled out as a
                           planning issue in some of the plans GAOreviewed. Without requiring that
                           ACECSbe considered in the planning process and without monitoring of
                           the ACECdecision-making process by the Bureau’s headquarters, GAO
                           believes the potential exists for continued inconsistencies in the future.



Principal Findings

Less Than Half the Plans   Over 13 years after the law that required them, the Bureau has com-
Are Completed              pleted only 63 of the 136 resource management plans for the public
                           lands. Another 42 plans were under development, and work has not
                           started on the remaining 31 plans. Between 1976 and 1980, the Bureau
                           developed planning regulations and initiated a number of pilot plans.
                           From fiscal year 1980 through fiscal year 1989, the Bureau has been
                           initiating work on an average of nine new plans per year.



                           Page   3                          GAO/RCED-90-226 Resource Management Planning
                            Executive Summary




                            During the 19809, the Bureau faced budget and staffing cutbacks that
                            hampered its ability to complete resource management plans. For
                            example, from fiscal years 1981 to 1989, the Bureau’s planning staff
                            was reduced by about 60 percent. The Bureau estimates that all plans
                            will be completed by 1997.


Limited Implementation of   When completed, the plans are to prescribe the goals and decisions for
Completed Plans             management of the public lands. However, for many of the goals and
                            decisions, the completion of the resource management plan is not an end,
                            but rather a beginning. The plans are typically general in nature, and
                            while providing a framework for managing the public lands, additional
                            steps are often needed to convert the goals and decisions contained in
                            the plans into on-the-ground actions. GAOfound that additional steps
                            including preparing project-specific plans, scheduling when actions will
                            take place, linking implementation actions to the budgetary process, and
                            tracking progress made had often not been accomplished for the com-
                            pleted plans it reviewed. For example, a goal of ensuring that wildlife
                            have adequate habitat has limited value if it does not identify the wild-
                            life species or geographical areas involved or the specifics of how or
                            when the goal will be achieved. During its review, GAOdiscussed the
                            need for a management control system for implementing completed
                            plans with Bureau officials. Subsequently, in July 1990, the Bureau
                            issued instructions requiring its field offices to: (1) prepare a plan imple-
                            mentation schedule no later than 90 days after plan approval, (2) link
                            plan implementation schedules to the budgetary process, and (3) track
                            and document progress in implementing the plans.


Inconsistent Designation    ELPMAdirected the Bureau to give priority to the designation and protec-
of Areas of Critical        tion of ACECSin the land-use planning process. GAOfound, however, that
                            the implementation of this legislative mandate has been inconsistently
Environmental Concern       applied. For example, 7 of the 14 plans GAOreviewed had not even iden-
                            tified ACECSas a planning issue. The Bureau’s guidelines implementing
                            the ACECconcept give its field office managers broad discretion in
                            designating sites on the public lands as ACECS.

                            GAOfound that decisions on designating important areas of the public
                            land as ACECSwere substantially dependent on the philosophical views
                            of Bureau field managers, which varied considerably, resulting in
                            widely disparate ACECdesignation decisions. For example, GAOfound
                            that one of the Bureau’s field offices had designated a western juniper/



                            Page 4                             GAO/RCED-90-225 Resource Management Planning
                  Executive Summary




                  sagebrush plant community as an AC%, even though such plant commu-
                  nities are considered common throughout many parts of the western
                  United States. In contrast, GAO found that another Bureau field office
                  had not designated a unique paleontological site as an ACEC.The site con-
                  tains foot tracks of pterodactyls, a form of flying reptile that became
                  extinct millions of years ago and is one of only four such sites that have
                  been discovered in the world.


                      recommends that the Secretary of the Interior instruct the Director,
Recommendations   GAO
                  Bureau of Land Management, to

                  closely monitor the implementation of its July 1990 resource manage-
                  ment plan instructions by the Bureau’s field offices and
                  require that ACECSbe specifically addressed and documented in the
                  resource management planning process, monitor the Bureau field
                  offices’ application of ACECguidance to achieve greater consistency
                  among the Bureau’s offices, and ensure that eligible areas of the public
                  lands are designated and protected as ACECS.


                  GAOmet with the Department of the Interior’s Deputy Assistant Secre-
Agency Comments   tary for Land and Minerals Management to obtain oral comments on this
                  report. The Deputy Assistant Secretary told GAOthat he agrees with the
                  report’s findings, conclusions, and recommendations. However, as
                  requested, GAOdid not obtain written agency comments on this report.




                  Page 6                            GAO/RCED-90-226 Resource Management Planning
Contents


Executive Summary                                                                                       2

Chapter 1                                                                                               8
Intr&duction                Background on the Bureau and Its Management of the                          8
                                Public Lands
                            FLPMA Revised Policy on Ownership and Management of                         9
                                the Public Lands
                            Resource Management Planning Process                                        9
                            Implementation of Plan Goals and Decisions                                 11
                            Areas of Critical Environmental Concern                                    12
                            Objectives, Scope, and Methodology                                         12

Chapter 2                                                                                              16
Progress Made in            Status of Resource Management Plans
                            Initial Steps in the Planning Process Took Several Years
                                                                                                       16
                                                                                                       16
Completing Resource         Bureau Planning Resources Reduced During the 1980s                         17
Management Plans            Competing Priorities Delayed Plan Completions                              18
                            Legislation Introduced to Establish a Planning Deadline                    20
                            Conclusions                                                                20

Chapter 3                                                                                              21
Limited                     Plan Implementation Actions Have Not Been Scheduled,                       21
                                Linked to Budgetary Resources, or Tracked
Implementation of           Bureau Initiatives to Improve the Plan Implementation                      26
Completed Resource              Process
Management Plans            Conclusions                                                                26
                            Recommendation                                                             26
                            Agency Comments                                                            26

Chapter 4                                                                                              27
Inconsistent          Treatment of ACECs Varied at Bureau
                      Bureau Revises ACEC Guidance
                                                                   Field Offices                       27
                                                                                                       31
Treatment of Areas of Conclusions                                                                      32
c&iCal  Environmental Recommendation                                                                   32
Concern               Agency Comments                                                                  32


AppendixesY                 Appendix I: Bureau Resource Management Plans                               34
                                Reviewed by GAO
                            Appendix II: Major Contributors to This Report                             36



                            Page 6                           GAO/RCED-SO-226 Resource Management Planning
          contenta




Tables    Table 1.1: The Bureau’s Resource Management Planning                      10
              Process
          Table 3.1: Elapsed Time in Plan Implementation Phase                      22
              and Implementation Schedule Status at the Time of
              GAO’s Visit to the Resource Area Offices
          Table 4.1: ACEC Designations Made or Planned in the 14                    28
              Plans GAO Reviewed
          Table 4.2: ACEC Designations as of September 30, 1989                     31

Figures   Figure 2.1: Status of the Bureau’s Resource Management                    16
               Plans, as of June 30,199O
          Figure 2.2: Bureau Planning Staff Full-Time Equivalent                    18
               Positions, Fiscal Years 1981-89




          Abbreviations

          ACEC       area of critical environmental concern
          ELS        Environmental Impact Statement
          FLPMA      Federal Land Policy and Management Act
          GAO        General Accounting Office


          Page 7                          GAO/RCED-90.226 Resource Management Planning
Chapter 1

Introduction                                                                                   ,


                    The total land area of the United States is 2.3 billion acres. Approxi-
                    mately one-third of this total, or 724 million acres, is owned by the fed-
                    eral government. The Department of the Interior’s Bureau of Land
                    Management is responsible for managing 270 of the 724 million acres,
                    including 176 million acres in 11 western states and 93 million acres in
                    Alaska. The remaining 1 million acres under the Bureau’s jurisdiction
                    are scattered throughout the country. The lands managed by the Bureau
                    contain many valuable resources including rangeland; timber; minerals;
                    watersheds; wildlife; fish; and scenic, cultural, recreational, and historic
                    sites. They represent a significant resource for the use and enjoyment of
                    present and future generations of Americans.


                    In July 1946, the Bureau of Land Management was established by con-
Background on the   solidating two existing federal agencies-the Grazing Service and the
Bureau and Its      General Land Office. The Bureau is responsible for administering federal
Management of the   lands that have not been set aside for specific uses, such as national
                    forests, national parks, national monuments, wildlife refuges, and
Public Lands        defense installations. The federal lands managed by the Bureau are com-
                    monly referred to as the “public lands.”

                    The public lands represent significant portions of several of the 11
                    western states, including 69 percent of Nevada, 42 percent of Utah, and
                    30 percent of Wyoming. The Bureau has divided the public lands, gener-
                    ally along state and county boundaries and natural geographic features
                    such as mountains and rivers, into separate resource areas. The
                    Bureau’s field operations are managed by state offices, district offices,
                    and resource area offices. Each of the Bureau’s 12 state offices is man-
                    aged by a state director. State offices are responsible for providing
                    statewide program direction, oversight, and coordination of resource
                    programs for federal lands under the Bureau’s jurisdiction. Each state
                    office has several district offices, each of which is managed by a district
                    manager. District offices provide their resource area offices with over-
                    sight and support. Resource area offices, each of which is managed by a
                    resource area manager, are the primary field locations responsible for
                    the day-to-day management of the public lands.




                    Page 8                             GAO/RCED-90-225 Resource Management Planning
                           Chapter      1
                           Introduction




                           Before the Federal Land Policy and Management Act of 1976 (FLPMA)
FLPMA Revised Policy       was passed, the Bureau managed the public lands custodially, pending
on Ownership and           their transfer to other federal agencies, states, or private ownership.
Management of the          Recognizing the value of the public lands to present and future genera-
                           tions of Americans, FLPMA established new policies and management
Public Lands               objectives governing the public lands, including the following:

                       .   Public lands would be retained in federal ownership.
                       .   Resources would be periodically and systematically inventoried.
                       .   Management would be on the basis of multiple use1 and sustained yield.2
                       .   Areas of critical environmental concern (ACEC) would be protected.

                           To implement this policy, FLPMAcalled for the development and use of
                           land-use plans for the management of the public lands and identified six
                           major land uses-livestock grazing, fish and wildlife development and
                           utilization, mineral exploration and production, rights-of-way, outdoor
                           recreation, and timber production.


                           In the late 196Os, recognizing the need for land-use planning to guide the
ResourceManagement         management of the public lands, the Bureau started to develop manage-
Planning Process           ment framework plans. These plans contained broad guidance for the
                           management of the public lands. When FLPMA required the development
                           of comprehensive land-use plans, the Bureau initiated a new planning
                           system that results in resource management plans. As designed,
                           resource management plans include a number of steps that were not spe-
                           cifically required under the management framework planning process.
                           Resource management plans have the following characteristics:

                       . They        are prepared in conjunction with an environmental impact state-
                         ment       (EN).
                       l They        include a formal process for public participation.
                       l They        deal specifically with resource conflicts.
                       . They        are consolidated in one document.
                       . They        are to address ACECSas a priority matter.



                           ‘Multiple-use management means management of the public lands and their various resources, such
                           as range, fish and wildlife, minerals, recreation, and timber, so that they are used in the combination
                           that will best meet present and future public needs.

                           2Sustained-yield management means achieving and maintaining in perpetuity a high level of annual
                           or regular periodic output of the various renewable resources of the public lands consistent with
                           multiple use.



                           Page 9                                          GAO/RCED-99-225 Resource Management Planning
                                          Chapter 1
                                          Introduction




                                         Essentially, the Bureau is preparing separate plans to cover the manage-
                                         ment of public lands in each resource area. There are exceptions, such as
                                         in Oregon, where, because resource areas are often small in size, one
                                         plan may cover as many as five resource areas. In total, the Bureau
                                         intends to prepare 136 plans to cover all the public lands.

                                         To complete a plan, the Bureau has established a nine-step resource
                                         management-planning process that takes several years to complete. For
                                         example, the initial seven plans completed in Colorado took an average
                                         of 39 months to prepare. Seven to 24 additional months were needed to
                                         resolve protests before the plans were finally approved. Table 1.1 shows
                                         the nine steps in the Bureau’s planning process.


Table 1.l : The Bureau’s Resource Manaaement
                                      -~     Plannlna Process
Step                                      Description
identify issues                          Solicit information from the public, industry, and government to identify issues or land-use
                                         problems, concerns, and conflicts
Develop blannina criteria                State the limits of what will or will not be considered durina the blannina brocess
Collect inventory data and information   Gather existing inventories and other data and identify other information to fill critical
                                         information gaps
Analyze the management      situation    Analyze inventory information in terms of the planning issues and management concerns
                                         being addressed in the plan
Formulate alternatives                   Develop a range of combinations of resource uses and management practices that respond
                                         to the planning issues
Estimate effects of alternatives         Combare and evaluate imbacts of each alternative on the environment
Select the preferred alternative         Recommend the alternative that best resolves the planning issues and promotes balanced
                                         multiple-use and sustained-yield objectives
Develop the plan                         Choose or modify the preferred alternative after analyzing public comments
Monitor and evaluate the resource        Track changes and trends in the environment caused by planning decisions and evaluate
management plan                          compliance with the plan, laws, and policies


                                         Development of resource management plans requires the involvement
                                         and input by officials from Bureau headquarters, and from state, dis-
                                         trict, and resource area offices. Operational responsibility for managing
                                         the development of resource management plans lies with the responsible
                                         resource area manager. In addition, Bureau, district, and state office
                                         officials are responsible for providing budget and staff support for the
                                         resource area offices and for providing guidance and quality control
                                         during the planning process. Plans are approved by the Bureau’s state
                                         director.




                                         Page 10                                    GAO/RCEDW225       Resource Management Planning
                    After a resource management plan is approved, the next step in the pro-
Implementation of   cess is for the Bureau to implement plan goals and decisions. Imple-
Plan Goals and      menting some goals and decisions requires the Bureau to merely
Decisions           continue what it had been doing before the plan was approved, with
                    some restrictions. Implementing others requires either specific actions
                    detailed in the plans themselves or additional planning before actual on-
                    the-ground actions can be taken.

                    Some plan goals and decisions can be implemented as a by-product of or
                    in conjunction with the Bureau’s routine field office operations. Activi-
                    ties such as issuing grazing permits, collecting grazing fees, approving
                    rights-of-way clearances for roads and utility corridors, and issuing
                    woodcutting permits are examples of routine operations. Although rou-
                    tine operations may not involve new initiatives, the Bureau considers
                    them to be part of the plan’s implementation process since they are to be
                    carried out in a manner that is consistent with the plan. According to
                    Bureau officials, approximately 86 to 90 percent of their resources are
                    dedicated to such routine operations.

                    Other plan goals and decisions fall outside the realm of routine opera-
                    tions but are so clearly detailed in the plan that they can be imple-
                    mented as soon as they are scheduled and funded. For example, the
                    Billings, Montana, plan called for acquiring legal rights to cross pri-
                    vately owned lands so that the public could get to a recreational fishing
                    area on Bureau-owned land. Thus, achieving this goal required only
                    scheduling when the easements or titles to the land would be obtained
                    and budgeting for the necessary funds.

                     Still other goals and decisions require additional planning before they
                     can be implemented. Many of the decisions and goals in resource man-
                     agement plans are general in nature and require additional project-spe-
                     cific plans before they can be implemented. For example, the Glenwood
                    Springs, Colorado, plan called for development and improvement of
                    water sources and riparian and waterfowl habitats but did not specify
                    the type or location of improvements needed. Therefore, a detailed pro-
                    ject-specific plan was needed to identify the specific type and location of
                    the improvements before the actual work could be undertaken.




                    Page 11                           GAO/RCED-90-226 Resource Management Planning
                                                                                                   ,


                            Chapter 1
                            Introduction




                            In passing FLPMA,the Congress recognized that there are special areas on
Areas of Critical           the public lands containing important resources or natural hazards
Environmental               where special management attention is needed to protect the resources
Concern                     or the public’s life and safety. In FLPMA,the Congress labeled these spe-
                            cial areas “areas of critical environmental concern” and directed that
                            their identification, designation, and protection be a priority.

                            For public land areas and sites to be eligible for ACECconsideration, the
                            Bureau’s regulations and implementing guidance establish three criteria
                            that must be satisfied. First, a site must be relevant. The Bureau defines
                            a relevant site as (1) one having a significant historic, cultural, or scenic
                            value; (2) a fish or wildlife resource or other natural system; or (3) a
                            natural hazard. Second, the relevant value, system, or hazard must be
                            important. The Bureau defines an important site as one that is of more
                            than local significance and worth. A natural hazard is considered impor-
                            tant if it is a significant threat to human life or property. Third, special
                            management must be needed to protect the relevant and important
                            values.


                            The Chairman, Subcommittee on National Parks and Public Lands,
Objectives, Scope,and       House Committee on Interior and Insular Affairs, asked us to assess
Methodology
                        l   the progress the Bureau has made in completing land-use plans (see ch.
                            21,
                        . whether the land-use plans that have been developed contain measur-
                          able goals and milestones (see ch. 3), and
                        l the progress the Bureau has made in designating ACECS(see ch. 4).

                            To determine the status of the Bureau’s land-use plans and the progress
                            the Bureau is making in completing the plans, we obtained information
                            from the Bureau’s planning office at the agency’s Washington, D.C.,
                            headquarters and its state offices.

                            To determine whether the land-use plans that have been developed con-
                            tain measurable goals and milestones, we reviewed 14 resource manage-
                            ment plans from among the 68 plans that were either approved or in
                            final draft form as of December 31, 1988. We selected two plans from
                            each of the seven states included in our review. One plan was developed
                            under supplemental planning guidance, which set specific plan content
                            requirements by program. These requirements were issued by the
                            Bureau to its field offices in November 1986. The other plan was devel-
                            oped before the guidance was issued. At the time of our field visits to


                            Page 12                            GAO/RCED-90-226 Resource Management Planning
Chapter 1
Introduction




the individual resource areas, 8 of these 14 plans had been approved in
final for at least 1 year. We selected the 7 states for our review to pro-
vide broad geographic coverage of the 11 western states. The states and
specific resource areas selected are shown in appendix I. The Bureau’s
Chief of Planning told us that the 14 plans we selected are a representa-
tive cross selection of the Bureau’s resource management plans.

To review the 14 plans in our sample in detail, we visited the 14 Bureau
resource area offices responsible for developing and implementing the
plans. In reviewing the 14 plans, as agreed with the Chairman, we con-
centrated on the consideration and coverage given to five areas: (1) live-
stock grazing, (2) wildlife, (3) recreation, (4) hard-rock minerals,3 and
(6) cultural resources. We also reviewed ACEC designations.

At each of the 14 resource area offices, we discussed plan preparation
with the resource area manager, the planning and ACEC coordinators,
and resource program specialists for grazing, wildlife, recreation, hard-
rock minerals, and cultural resources. We examined resource manage-
ment planning records and documents including preplanning records,
management situation analysis summaries, draft plans, and resource
inventory records and public comments.

For the eight plans that had final approval for at least one year at the
time of our field visits, we reviewed the final approval decision, plan-
monitoring records, and activity and other implementation records and
schedules, and discussed implementation of the plan with resource area
office officials. We also visited several designated and potential ACEX
sites and discussed the issues of ACEC identification and designation with
representatives of State Historic Preservation Offices and various
interest groups such as The Nature Conservancy and the Natural
Resources Defense Council. We reviewed the Bureau’s regulations,
guidelines, and instructions issued by headquarters and its state offices
concerning public land resource inventories, land-use planning, and spe-
cial management areas such as ACECS.

As agreed with the Chairman, we did not obtain written comments on a
draft of this report from the Department of the Interior but obtained
oral comments from the Department’s Deputy Assistant Secretary for
Land and Minerals Management, and incorporated them into the report.
Our review was conducted from June 1988 through September 1989 in
accordance with generally accepted government auditing standards. We

“Includes mining for minerals such as gold, silver, and copper.



Page 13                                        GAO/RCED-90-226 Resource Management Planning
chapter1
Introduction




also updated certain information contained in this report through July
1990.




Page 14                          GAO/RCRD-f&225 Besource Management Planning
       .

Chapter 2

&ogress Made in CompletingResource
ManagementPlans

                     As of June 30,1990, the Bureau had completed 63 of the 136 resource
                     management plans it intends to prepare to guide the management of the
                     public lands. Between 1976 and 1979, the Bureau developed planning
                     regulations and initiated a number of pilot plans. From fiscal year 1980
                     through fiscal year 1989, the Bureau initiated work on an average of
                     nine (ranging from 6 to 16) new plans per year.

                     The planning process requires input not only by the Bureau’s planning
                     staff but by resource specialists such as biologists, archeologists, and
                     range conservationists as well. During the 198Os, budget and staffing
                     cutbacks hampered the Bureau’s ability to develop resource manage-
                     ment plans. For example, from fiscal year 1981 to fiscal year 1989, the
                     Bureau’s planning staff was reduced by half from 366 full-time
                     equivalent staff to 179.

                     FLFWAdid not establish mandatory completion dates for the plans, and
                     competing work demands for the Bureau’s staff as well as resource limi-
                     tations were factors in plan delays. Legislation that would establish
                     mandatory completion dates has been introduced in the Congress, but as
                     of June 30, 1990, it had not been enacted. According to the Bureau’s
                     estimates as of June 1990, it will complete all 136 resource management
                     plans by 1997.


                     According to Bureau officials, of the 136 scheduled resource manage-
Status of Resource   ment plans, 63 had been completed, 42 were in process, and 31 had not
Management Plans     yet been started as of June 30, 1990. (See fig. 2.1.) The Bureau plans to
                     begin work on the 31 unstarted plans by fiscal year 1996 and anticipates
                     completing all the plans by fiscal year 1997.




                     Page 15                          GAO/RCED-90-226 Resource Management Planning
                                        Chapter 2
                                        Progress Made in Completing Resource
                                        Management Plan9




Figure 2.1: Status of the Bureau’8
Rerource Management Plane, a8 of June
30,199o                                                                              63 completed




                                            I46%




                                        From 1976, when FLPMAwas enacted, through 1979, the Bureau pre-
Initial Steps in the                    pared regulations to guide the preparation of the resource management
Planning ProcessTook                    plans. Final regulations were published in August 1979. In 1979, the
Several Years                           Bureau also started work on the first of six pilot resource management
                                        plans. According to Bureau sources, extra time and resources were
                                        devoted to these pilot plans because field staff were developing the
                                        plans through an undefined process, The Bureau completed the first
                                        pilot plan-for the Glenwood Springs resource area in Colorado-in
                                        1984. While the Bureau was working on the pilot plans, it also initiated
                                        work on five nonpilot plans in fiscal year 1980, and an average of about
                                        nine (ranging from 5 to 15) new plans per year each year thereafter,
                                        through fiscal year 1989.

                                        The preparation of resource management plans is time-consuming. The
                                        plan preparation phase of this process comprises several products and,
                                        according to a Bureau planning official, it takes about 4 years to com-
                                        plete a plan. The first product, is a draft plan and EIS, which takes an
                                        average of about 2 years to prepare. Preparing the draft plan is the most
                                        time-consuming part of the plan preparation process since Bureau staff
                                        must identify issues to be addressed in the plan, collect information,
                                        identify management alternatives, conduct an environmental assess-
                                        ment, and draft the plan.




                                        Page 16                                GAO/RCED-90-226 Resource Management Planning
    .


                   chapter 2
                   Progress Mnde in Completing Resource
                   Management Plans




                   The next product of this phase (the proposed plan) takes an average of
                   about 9 months to complete. To complete this product, public comments
                   on the draft are evaluated and the Bureau selects the preferred land
                   management approach from the alternatives presented in the draft plan.

                   During the development of the last product of this phase, which aver-
                   ages about 11 months to complete, the public is allowed to file protests
                   with the Bureau for objections to all or part of the plan. If a protest
                   results in significant changes to the proposed plan, an additional public
                   comment period is provided. Once all protests are resolved, the Bureau’s
                   state director approves the plan, which then becomes the operable
                   resource management plan for the area.


                   In 1980, the Bureau began its full-scale effort to develop resource man-
Bureau Planning    agement plans. However, rather than experiencing an increase in
ResourcesReduced   resources to perform this expanded workload, the Bureau experienced a
During the 1980s   reduction in the staff resources needed to perform this work.

                   During the 198Os, the Bureau experienced reductions in both the
                   funding and staff resources available for the planning function. In fiscal
                   year 1981, the Bureau had a planning staff of 366 full-time equivalent
                   positions. By fiscal year 1989, the staffing level had been reduced to 179
                   full-time equivalent positions, or a SO-percent reduction. The largest
                   reduction in the planning staff levels occurred from fiscal year 1981 to
                   fiscal year 1982, when the planning staff was reduced by 122 full-time
                   equivalent positions.




                   Page 17                                  GAO/RCED-90-225 Resource Management Plauuhg



                                                ‘.        .:,
                                           Chapter 2
                                           Progress Made in Completiug Resource
                                           Management Plans




Figure 2.2: Bureau Plannlng Staff Full-
Time Equivalent Podtions, Flrcal Year8
                                          4QQ      FTES
1991-89
                                          33Q


                                          900

                                          260


                                          200


                                          150


                                          100




                                            1981          1982   1983      1884     1985      1926      lQQ7     1QQQ      1988
                                            Fiscal Yssn



                                          To cope with the staffing reductions, the Bureau made a number of
                                          policy decisions affecting the resource management-planning process.
                                          Specifically, the Bureau streamlined the process by deciding to rely on
                                          existing inventory data to the extent possible, rather than developing
                                          new data on the resources on the public lands. The Bureau also decided
                                          to streamline the planning process by focusing the plans on issues that
                                          were considered critical for a given resource area, rather than on all
                                          potential issues. For example, the plan for the Glenwood Springs, Colo-
                                          rado, resource area that was started in 1979 addressed 21 issues,
                                          whereas the plan for the Cody, Wyoming, resource area, started in 1986,
                                          addressed only 3 issues.


                                          Because competing work demands on the Bureau’s staff have received
Competing Priorities                      higher priority, completion of the Bureau’s resource management plans
Delayed Plan                              has been delayed. To develop resource management plans, the Bureau
Completions                               uses planning teams that comprise specialists such as range conserva-
                                          tionists, wildlife biologists, and archeologists. In addition, Bureau dis-
                                          trict and state officials are responsible for supervising and coordinating
                                          the development of the plan. The Bureau’s specialists who participate in
                     Y                    the development of resource management plans also have responsibili-
                                          ties for day-to-day or routine management of their individual program



                                          Page 18                                 GAO/RCED-90-226 Resource Management Planning
    .

.       Chapter 2
        Progresr Made in Completing Resource
        Management Plans




        areas. For example, rangeland managers typically have responsibility
        for administering grazing permits, managing range improvement
        projects, and monitoring the condition of grazing allotments, in addition
        to providing input on grazing for the resource management plan,

        The specialists’ routine responsibilities may have established deadlines,
        For example, a range conservationist must authorize grazing levels and
        process bills for grazing fees, often for hundreds of permittees. As a
        result, work on the resource management plan is at times deferred in
        favor of more urgent responsibilities.

         This problem is exacerbated by the fact that for some of its programs,
        there are not enough Bureau specialists to perform even routine respon-
        sibilities much less devote the additional time required for resource
        management planning. For example, we have previously reported that
        limited staff resources had contributed to slow progress in protecting
        and improving riparian areas -narrow bands of green vegetation along
        the banks of rivers and streams and around springs, bogs, lakes, and
        ponds, Bureau staff told us that they could not give enough effort to
        riparian area management because of other competing demands on their
        time.’ Similarly, we have also reported that staffing constraints have
        limited the Bureau’s ability to manage livestock grazing allotments (sep-
        arate grazing units). Bureau range managers told us that limited staff
        resources prevented them from monitoring all grazing allotments and
        that they were unable to adequately monitor even those allotments
        targeted for intensive management. For example, Bureau range man-
        agers at the Nevada State Office told us that Bureau staff made annual
        monitoring visits to only about one-third of their allotments, They said
        that many allotments targeted for intensive management were not vis-
        ited each year and that staffing shortages usually prevented other allot-
        ments from being monitored.2

        Six of the 14 resource management plans we reviewed in detail experi-
        enced delays. While there were a number of reasons for these delays,
        other competing priorities and/or resource limitations were a factor in
        each of these delays. For example, work on the Phoenix, Arizona, draft
        resource management plan was scheduled to be completed in 1986, but
        was not actually completed until 1988 because, according to a Bureau

        ‘Public Ran elands: Some Riparian Areas Restored but Widespread Improvement Will Be Slow
        @We         _88_105 , June 30,1988).

                          ment: More Emphasis Needed on Declining and Overstocked Grazing Allotments




        Page 19                                    GAO/RCED-90-226 Resource Management Planning
                         chapter2
                         Progreaa Made in Completing Renource
                         Management Phuu




-
                         official, staff had to postpone work on the plan to assist with fire
                         fighting.


                         Concern about the pace of developing resource management plans
Legislation Introduced   resulted in a bill which was introduced in the Congress in 1989 that
to Establish a           would establish mandatory completion dates for the plans. FLPMAhad
Planning Deadline        not established a date for completing resource management plans. The
                         bill-H.R. 828-proposes to amend FWMAby requiring that

                         Land use plans meeting the requirements of this Act shah be developed
                         for all the public lands outside Alaska no later than January 1,1997,
                         and for all public lands no later than January 1,1999.

                         The bill was passed by the House of Representatives in 1989, and as of
                         June 1990, was awaiting action by the Senate.


                         More than 13 years after FLPMA was enacted, the Bureau has completed
Conclusions              less than half of the resource management plans needed to guide the
                         management of the public lands. A number of factors have contributed
                         to this limited progress. Among them are significant reductions in
                         staffing available to work on plan development (60 percent from fiscal
                         year 1981 to fiscal year 1989), and competing program priorities and
                         resource limitations. As of June 30, 1990, the Bureau estimated that it
                         will complete all 136 resource management plans by 1997.




                         Page 20                                GAO/RCEDBO-226 Reaounx Management Planning
Limited Implementation of Completedl3esource 1
ManagementPlans                   .

                           When completed, the Bureau’s resource management plans establish the
                           goals and decisions for managing the public lands. However, the plans
                           are of limited practical value unless the Bureau takes actions to effec-
                           tively implement them once approved, In other words, the completion of
                           the resource management plan is not an end in itself, but rather a
                           beginning.

                           For the completed plans we reviewed, the Bureau had made only limited
                           progress in converting approved plan goals and decisions into on-the-
                           ground actions. Specifically,

                       l schedules showing when implementation actions for approved plans
                         would take place typically had not been developed,
                       . implementation actions had not been linked to the budgetary resources
                         necessary to carry them out, and
                       . progress made in implementing the plans was typically not tracked or
                         monitored.

                           The absence of an effective management control system to ensure that
                           the specific actions needed to implement approved resource manage-
                           ment plans that are scheduled, funded, and tracked had contributed to
                           these shortcomings. In July 1990, the Bureau issued plan implementa-
                           tion instructions to its field offices that address these shortcomings.


                           To ensure that plan goals and decisions are implemented in an orderly
Plan Implementation        and timely manner, the Bureau needs to schedule them, provide the
Actions Have Not           resources to carry them out, and monitor or track their implementation
Been Scheduled,            progress. However, we found that (1) most of the Bureau’s field offices
                           we reviewed in detail had not developed plan implementation schedules,
Linked to Budgetary        (2) an effective plan implementation/budget interface does not exist,
Resources,or Tracked       and (3) progress in implementing the plans was not being effectively            t
                           monitored or tracked.


Plan Implementation        As shown in table 3.1, six of the eight plans we reviewed that had
Actions Often Not          received final approval had not established schedules for implementing
                                                                                                           .
                           their resource management plans.             ’
Scheduled




                           Page 21                          GAO/RCED-SO-226 Resource Management Planning
                                        Chapter 3
                                        Limitd hplementatlon  of Completed
                                        Resource Management Plane




Table 3.1: Elapsed Time in Plan
implementation Phase and                                                                                  im lementation
impiementation Schedule Status at the                                              Elapsed time rlnce     SCReduie
Tlme of QAO’s Visit to the Resource     Rerource management plans            approval of plan (months)    developed
Area Offices                            Glenwood ScAnas, Cola.                                      58    No
                                        Hollister, Calif.                                           58    Yes
                                        Billings, Mont.                                             49    No
                                        Platte River, Wyo.                                          45    No
                                        John Dav, Orea.                                             43    No
                                        Lahontan, Nev.                                              38    Yes
                                        Yuma, Ark.                                                  33    No
                                        Elko. Nev.                                                  20    No


                                        The Platte River, Wyoming, plan, approved in July 1986, called for
                                        developing an implementation schedule by September 1986. About 4
                                        years after the plan was approved, we found that an implementation
                                        schedule had not been developed. The field office official responsible for
                                        the schedule told us that he had started to develop an implementation
                                        schedule but suspended his efforts in 1986 because the Bureau’s Wyo-
                                        ming State Office was developing a plan-scheduling system. However, as
                                        of May 1989, the state system had not been developed, and the resource
                                        area office had not resumed its efforts. We also found that five other
                                        plans that had been approved for at least 1 year at the time of our visits
                                        did not have detailed implementation schedules. For example, the
                                        resource area manager at Glenwood Springs, Colorado, told us that an
                                        implementation schedule for the plan approved in 1984 had not been
                                        established because of changing priorities and funding and staffing
                                        uncertainties. Specifically, he said he did not want to establish schedules
                                        because they probably would not be met.

                                        Without a schedule, however, even relatively straightforward plan deci-
                                        sions that can be implemented through routine operations may remain
                                        unimplemented. For example, the Glenwood Springs, Colorado, plan
                                        called for removing livestock from 44 specific grazing allotments by
                                        October 16th of each year to provide winter rangeland for wildlife. This
                                        decision easily could have been implemented as a by-product of the rou-
                                        tine annual grazing authorization process. However, at the time of our
                                        visit to Glenwood Springs (nearly 6 years after the plan had been
                                        approved), the resource area range specialist told us that these grazing
                                        season adjustments had not been made.

                                        In contrast, the Hollister, California, resource area office had developed
                                        for its plan a S-year implementation schedule, which was approved in


                                        Page 22                                GAO/RCED-90-225 Resource Management Planning
      .


                        chapter   8
                        Jhnitd Implementation of Completed
                        Reaource Management Plans




                        August 1984. While implementation schedules do not guarantee that
                        actions will be completed by their scheduled dates, they do provide the
                        Bureau, the Congress, and the public with an opportunity to measure
                        progress against established milestones.


Plan Implementation     Accomplishing specific actions to implement plan goals and decisions
Actions Not Linked to   also requires their translation into staffing and funding requirements
                        needed to carry them out. A plan goal to manage recreation activities in
Budgetary Resources     a resource area has little practical effect if the resources needed to carry
                        out specific recreation projects are not identified, requested, and pro-
                        vided. For example, the John Day, Oregon, plan approved in 1986, called
                        for designating and fencing a specific area for off-road vehicle use to
                        limit environmental impacts to the fenced area. However, 4 years after
                        the plan was approved, this project had not been funded.

                        Bureau headquarters officials told us that there had been a disconnec-
                        tion between plan implementation actions and budgets necessary to
                        carry them out. This disconnection was evident at the Bureau resource
                        area offices we visited. For example, the Glenwood Springs, Colorado,
                        Resource Area Office staff told us they provide little input to the budget
                        process. Staff at the Grand Junction District Office, the next higher field
                        office level, said their input into the budget process consists of an
                        informal listing of the district’s general priorities.

                        The resource area manager at Billings, Montana, told us that any link
                        between annual funding and plan implementation was coincidental
                        because most funding is tied to routine field office operations. Plan
                        implementation is thus a coincidental by-product of the Byreau’s budget
                        process rather than a front-end consideration.

                        In 1980, we issued a report that emphasized the need for an effective
                        linkage between the Bureau’s plans and annual budgets.* In that report,
                        we stated that the Bureau recognized the need for linking plans and
                        budgets but that efforts to establish links between the plans and budgets
                        had been delayed because existing land management plans did not pro-
                        vide sufficient quantifiable data which could be related to budget
                        requirements. At that time, Bureau officials told us they hoped to imple-
                        ment a system to link the plan with the budget within 5 to 7 years. In


                        ‘Changes in Public Land Management Required to Achieve Congressional Expectations (CED-80-82 &
                        %!A, July 16,198O).



                        Page 23                                    GAO/RCED-90-226 Resource Management Planning
                           chapter 3                                                                    .
                           Limited Implementation of Completed
                           Resource Management Plane




                           July 1990, the Bureau issued instructions that provide for linking the
                           planning and budgeting processes.


Progress in Implementing   Monitoring and tracking a plan provides an important management con-
Plans Not Monitored or     trol for measuring the progress made in implementing its goals and deci-
                           sions, The Bureau’s resource management-planning instructions require
Tracked                    that a system be established to track plan implementation progress.
                           However, the Bureau field offices responsible for six of the eight com-
                           pleted plans we reviewed had not established effective tracking systems
                           to provide the basic information necessary to assess whether plan
                           implementation was on, ahead of, or behind schedule.

                           The Lahontan, Nevada, resource management plan was one of the two
                           that had established a tracking system to provide the resource area
                           office manager with information on the status of plan implementation.
                           The Lahontan plan was approved in 1986, and an implementation and
                           tracking system was started in 1987. This system provides information
                           on specific actions scheduled for implementation, including planned and
                           actual completion dates. Implementation actions on the schedule include
                           those contained in the plan itself as well as those contained in project-
                           specific plans. For example, under the wildlife program, implementation
                           actions scheduled for 1990 include developing one habitat management
                           plan; revising another habitat management plan; and completing five
                           projects to improve riparian, sage grouse, and deer habitat. The system
                           also allows for identifying actions that were scheduled but not fully
                           implemented. For example, two grazing allotment management plans
                           and one wild horse herd management plan were scheduled for 1988, but
                           the tracking system revealed that these actions had not been completed.

                           In contrast, the other six Bureau field offices had less sophisticated
                           tracking systems. Typically, the tracking systems at these six offices
                           consisted of log books that had separate sheets for each plan goal and
                           decision. While the log books showed when an action had been taken,
                           they identified neither all needed actions nor the time frames for their
                           completion. Thus, the status of the plan’s implementation is not readily
                           measurable.




                           Page 24                               GAO/RCED-90-225 Resource Management Planning
                          Chapter 8
                          Llmbd Implementation      of Completed
                          Reeource   Management   Plane




                          Bureau headquarters officials have recognized for some time the need to
Bureau Initiatives to     strengthen the plan implementation process. In March 1989, the
Improve the Plan          Bureau’s headquarters planning staff developed draft instructions for
Implementation            plan implementation and requested comments on the draft proposal
                          from the Bureau’s state offices. In July 1990, the instructions were
Process                   issued in final to the Bureau’s field offices.

                          The Bureau’s July 1990 instructions call for

                        . developing plan implementation           schedules no later than 90 days after
                          plan approval,
                        . linking plan implementation schedules to the budgetary process, and
                        . tracking and documenting progress made in implementing the plan.

                          These instructions, if properly implemented, should address many of the
                          shortcomings in implementing the resource management-planning pro-
                          cess discussed in this chapter.


                          The goals and decisions contained in the Bureau’s resource management
Conclusions               plans for the management of the public lands are of little practical value
                          unless steps are taken to convert the conceptual ideals of approved
                          plans into on-the-ground actions. In essence, the issuance of an
                          approved resource management plan should not be viewed as an end but
                          rather as a beginning. During our work, we found that the Bureau has
                          made only limited progress in taking the actions necessary to implement
                          the approved resource management plans we reviewed. Schedules for
                          implementing actions typically had not been developed, implementing
                          actions had not been linked to the budgetary resource requirements nec-
                          essary to carry them out, and progress made in implementing plan goals
                          and decisions had typically not been tracked. Without these follow-on
                          actions, the process of developing the resource management plans is
                          little more than a paper exercise and the plans themselves little better
                          than reference documents. During our review, we discussed the need for
                          these follow-on actions with Bureau officials, and in July 1990, the
                          Bureau issued plan implementation instructions to its field offices,
                          which, if properly implemented, would address many of the problems
                          discussed in this chapter.


                          We recommend that the Secretary of the Interior instruct the Director,
Recommendation            Bureau of Land Management, to closely monitor the implementation of



                          Page 25                                  GAO/RCED-90-226 Resource Management Plaunhg



                                                         .*                                                 L
                  chapter 8
                  LImIted Implementation of Completed
                  Resource Management Plans




                  the Bureau’s July 1990 resource management plan instructions by the
                  Bureau’s field offices.


                  The Department of the Interior’s Deputy Assistant Secretary for Land
Agency Comments   and Minerals Management said he agrees with this recommendation.




                  Page 26                               GAO/RCED-90-226 Resource Management Planuing
InconsistentTreament of Areas of Critical
l3nvironmentaJConcern

                         FLPMAdirected the Bureau to give priority in the land-use planning pro-
                         cess to designating and protecting areas of critical environmental con-
                         cern. ACECSare areas on the public lands that require special
                         management attention to protect or prevent irreparable damage to
                         important resources, such as historic and cultural sites, or to protect the
                         public’s life and safety from natural hazards such as avalanches and
                         landslides.

                         The treatment of ACES in the resource management-planning process
                         varied considerably among the 14 Bureau plans we reviewed. For
                         example, in some plans, the Bureau’s field offices had identified ACECSas
                         a planning issue and had documented the process of identifying and
                         designating ACECS.Other field offices, however, had not identified ACECS
                         as a planning issue and had handled the ACECprocess informally, with
                         little or no documentation of what areas were considered for designation
                         or how final decisions were made. We found that the broad latitude
                         given to the Bureau’s field offices in designating ACES, combined with
                         philosophical differences between Bureau field office managers on the
                         need for and importance of designating and protecting such sites, were
                         important factors contributing to the inconsistencies we found.

                         In 1986, the Bureau recognized that its field offices had been inconsis-
                         tent in handling the ACECissue, and in September 1988 the Bureau
                         issued revised ACECguidance to its field offices. However, the root
                         causes of the inconsistencies we observed-substantial      field office deci-
                         sion-making discretion and philosophical differences between Bureau
                         field office managers- still exist. Consequently, there is a need for the
                         Bureau’s headquarters to closely monitor the application of the revised
                         guidance at its field offices to ensure consistency in designating eligible
                         areas of the public lands as ACES.


                         The 14 Bureau resource area offices we visited had given widely dispa-
Treatment of ACECs       rate treatment to the identification, evaluation, and designation of
Varied at Bureau Field   ACECS.Although FLPMAcalls for the Bureau to give priority to ACECSin
Offices                  the planning process, 7 of the 14 plans we reviewed had not singled out
                         IU=ECS  as an issue to be addressed. The degree to which this meant that
                         eligible areas were not designated as ACECSwas not readily quantifiable.

                         Only 3 of the 14 plans we reviewed (Yuma in Arizona, Brothers-LaPine
                         in Oregon, and Cody in Wyoming) had documented their ACECcandidate
                         identification and designation decision-making process in any detail. For



                         Page 27                            GAO/RCED-90-225 Resource Management Planning
                                       Chapter 4
                                       Inwrurifdent Treatment of Areas of Critical
                                       Edronmental     Concern




                                       the other 11 plans, documentation of the ACECidentification and desig-
                                       nation process was typically made informally with little or no documen-
                                       tary evidence.

                                       We did, however, review what documentation was available and dis-
                                       cussed ACEC identifications and designations with the Bureau’s field
                                       office specialists and managers. For example, the plan for Uncompaghre
                                       Basin, Colorado, did not have documentary evidence of the ACECidentifi-
                                       cation, evaluation, and designation process. Because documentation was
                                       lacking, we discussed how ACES were dealt with during plan develop-
                                       ment with the field office staff. They told us that designating ACECsites
                                       was not a high priority. According to them, there was no specific solici-
                                       tation of ACECcandidate sites from either the public or Bureau staff. One
                                       member of the planning team was assigned responsibility for identifying
                                       ACECcandidates on the basis of the team members’ personal knowledge
                                       of the resource area. No list or other record was prepared for the candi-
                                       date sites considered.

                                       Some of the Bureau’s resource area offices that we visited had desig-
                                       nated many areas as ACECS,while others had designated none. Table 4.1
                                       shows the number of ACECdesignations that have been made or that are
                                       planned for the 14 plans we reviewed.

Table 4.1: ACEC Derlgnstlons Made or
Planned in the 14 Plans GAO Reviewed   Resource management plan                                                Number of ACECs
                                       Brothers-LaPine, Oreg.                                                                 12
                                       Arcata, Calif.                                                                          7
                                       Phoenix, Ariz.                                                                          7
                                       Glenwood Springs, Cola.                                                                 6
                                       Cody, Wyo.                                                                              5
                                       Uncompahgre Basin, Cola.                                                                4
                                       Hollister, Calif.                                                                       3
                                       Lahontan, Nev.                                                                          3
                                       Platte River, Wyo.                                                                      2
                                       West HiLine, Mont.                                                                      2
                                       Yuma, Ariz.                                                                             1
                                       Billings, Mont.                                                                         0
                                       Elko, Nev.                                                                              0
                                       John Day, Oreg.                                                                         0
                                       Total                                                                                  52
                  J




                                       Page 28                                       GAO/WED-SO-226 Resource Management Planning
Chapter4
Inconaietent Treatment of Areas of Critical
Jhvironmental Concern




We found that philosophical differences between the Bureau’s field
offices were a significant factor in whether relevant and important sites
on the public lands were designated as ACECS. For example, the Brothers-
LaPine resource area office covers 1.1 million acres of public land in
Oregon and is illustrative of a resource office that apparently empha-
sized ACECdesignations. The resource management plan designated 12
ACEXSof various sizes and types including a site containing basalt forma-
tions, Indian pictographs, and primitive recreation resources; a site con-
taining recreation, riparian, and fishery resources; a site containing
sensitive plants; and a site containing a western juniper/sagebrush plant
community, a resource that is common throughout many parts of the
western United States.

At Billings, Montana, where the plan covers 432,000 acres of public land
in the state, the resource area manager told us that all,of the potential
ACEC sites identified within the resource area can be adequately pro-
tected without ACEC designation and special management. However,
there is a site within this resource area that, according to the Bureau’s
resource area archeologist, possibly meets the ACEC eligibility criteria
but was not designated. Weatherman Draw is an area of approximately
7,700 acres containing a cluster of over 60 American Indian rock art
sites. The area was not designated as an ACEC in the resource manage-
ment plan even though the Bureau’s resource area archeologist at the
time considered the initial eight sites inventoried to be unique and a sig-
nificant source of archeological data on little understood aspects of
early Northwestern Plains Indian behavior. The current archeologist
told us that 40 additional rock art sites have been identified and that the
resource values at Weatherman Draw qualify as an ACEC.However, the
resource area manager told us that he does not plan to designate the
sites as an ACEC because he believes they can be adequately protected by
routine management.

At Elko, Nevada, where the plan covers 3.1 million acres of public land
in the state, a number of areas contain important values but were not
designated as ACECS.The Elko resource area office archeologist told us
that the resource area contains a number of cultural sites that he
believes should have been designated as ACECS,including a unique rock
quarry that had been used for centuries by Native Americans for tool-
making and a rare stratified deposit of ash from the volcanic eruption
that formed Crater Lake. The Elko district office manager told us that
no ACECSwere designated because the Bureau’s Nevada State Director
was generally opposed to ACEC designations and because of his belief



Page 29                                       GAO/RCED-99-225 Resource Management Planning
Chapter 4                                                                            .
Iuconaietent Treatment of Areas of Critical
EnvIronmental Concern




that all resources could be adequately protected by standard or routine
management or other statutory authorities.

The Bureau’s Platte River, Wyoming, resource area includes a site con-
taining pterodactyl tracks. Pterodactyls were a form of flying reptile
that became extinct millions of years ago. Foot tracks of these animals
are very rare; only four sites containing such tracks have been found in
the world. Recognizing that this site was unique and could be destroyed
by indiscriminate collection, vandalism, or mining, the Bureau desig-
nated the area as an ACECin 1980. However, the Platte River resource
management plan removed the ACEC designation for this site in 1986.
Bureau resource area officials told us that in designating the pterodactyl
tracks as an ACECin 1980, it was thought that the designation would
result in additional funding from headquarters for site management.
They said that the additional funding never materialized, so the ACEC
designation was dropped. The area is currently unprotected.

Overall, ACECdesignation, which also vary considerably among the
Bureau’s state offices, reflect different philosophical approaches toward
ACECSamong the Bureau’s state offices, For example, in a 1986 memo-
randum, the Bureau’s Nevada State Office Director said that some states
such as California and Oregon have interpreted FLPMA quite liberally and
have designated ACECSon a wholesale basis. He contrasted those states
to Nevada, which has taken the position that existing management
actions are sufficient to adequately protect sensitive resources on the
public lands. Operationally, the Nevada State Office Director had
instructed the Bureau’s Nevada district offices specifically not to pro-
pose the designation of wildlife areas such as sage grouse strutting
grounds, bighorn sheep habitat, or desert tortoise habitat as ACECS,when
other management options are available.

During our work, we found that several areas had been designated as
ACECSin one state but that areas with similar values had not been desig-
nated in other states. Among the Bureau’s state offices, the number of
sites designated as ACECSranged from 106 in California and 99 in
Oregon, to 4 in Montana, and 6 in Nevada. Table 4.2 shows the ACEC
designations for 11 western states aa of September 30,1989.




Page 30                                       GAO/RCED-30.226 Resource Management Planning
    h
                                        Chapter 4
                                        IneoneW.ent Treatment of Areas of Critical
                                        Environmental Concern




Table 4.2: ACEC Designations as of
September 30,1969                      State                                                                   Number designated
                                       California                                                                              105
                                       Oregon                                                                                   99
                                       Idaho                                                                                    58
                                       New Mexico                                                                               57
                                       Colorado                                                                                 32
                                       Wyoming                                                                                  23
                                       Alaska                                                                                   18
                                       Utah                                                                                     17
                                       Arizona                                                                                  10
                                       Nevada                                                                                    6
                                       Montana                                                                                  4
                                       Total                                                                                  429



                                       In 1986, the Bureau recognized that its field offices had been inconsis-
Bureau Revises ACEC                    tent in their treatment of ACECS in the planning process. The Bureau
Guidance                               believed that confusion and uncertainty about ACF& requirements and
                                       procedures accounted for the disparity between its field offices.

                                       To address the problems it had identified, the Bureau revised its ACEC
                                       guidance to its field offices in September 1988. Since all of the 14 plans
                                       we reviewed in detail either had been approved or were published in
                                       draft as of September 1988, we were unable to determine whether the
                                       new ACECguidance would overcome the inconsistencies that both we and
                                       the Bureau have observed. However, the new guidance still gives the
                                       Bureau’s field offices substantial discretion in the ACEC decision-making
                                       process. For example, the new guidance allows field managers to decide
                                       not to designate otherwise relevant and important areas if

                                     . they conclude that the area or value can be sufficiently protected with
                                       standard or routine management;
                                     . the area is being proposed for designation under another statutory
                                       authority, such as a wilderness designation;
                                     . they conclude that no special management attention is justified because
                                       exposure to risks of damage or threats to safety are greater if the area is
                                       designated (i.e., by drawing additional public attention to it); or
                                     . they conclude that there are no reasonable special management actions
                                       that can be taken to protect the resource from irreparable damage or to
                                       restore it to a viable condition.




                                       Page 31                                       GAO/RCED-90-228 Resource Management Plauning
                       chapter 4
         .             ~hcondstent Treatment of Areas of Critical
                       Environmental Concern




                       Thus, to the extent that individual field office managers are philosoph-
                       ically disinclined to designate ACECS,the reasons allowing nondesigna-
                       tion listed above provide sufficient justification for their decisions.


                       FLPMAdirected the Bureau to give priority to the designation and protec-
    Conclusions        tion of ACECSin the land-use planning process. The implementation of
                       this legislative mandate, however, has been inconsistently applied. For
                       example, 7 of 14 plans we reviewed had not even identified ACECSas a
                       planning issue. The Bureau’s field office managers have used the broad
                       discretion afforded them under the Bureau’s guidance to make widely
                       disparate ACEC decisions.

                       The Bureau revised its ACIX guidance in September 1988 to address past
                       inconsistencies, but the guidance still gives the Bureau’s field offices
                       substantial discretion in making ACEC decisions. While we do not dispute
                       the basic concept of decentralized decision-making, we believe there is a
                       need for the Bureau to take those steps necessary to ensure that its field
                       offices handle their treatment of ACECSconsistently to ensure that eli-
                       gible areas of the public lands are identified, evaluated, and appropri-
                       ately designated and protected.


                       We recommend that the Secretary of the Interior instruct the Director,
.   Recommendation a   Bureau of Land Management, to (1) require that ACECSbe specifically
                       addressed and documented in the resource management planning pro-
                       cess and (2) monitor the Bureau field offices’ application of ACXCgui-
                       dance to ensure greater consistency among the Bureau’s offices in the
                       process and to ensure that eligible areas of the public lands are desig-
                       nated and protected as ACECS.


                       The Department of Interior’s Deputy Assistant Secretary for Land and
    Agency Comments    Minerals Management said he agrees with this recommendation.




                       Page 32                                      GAO/RCED-90-225 Resource Management Planning
Page 88   GAO/RCED-90-225 Resource Management Planning
Appe ndix I

Bureau ResourceManagementPlans Reviewed
by GAO

              State        Resource manaaement Plan
              Arizona      Phoenix and Yuma
              California   Arcata and Hollister
              Colorado     Glenwood SDrinas and UncomDahare Basin
              Montana      Billinas and West-HiLine
              Nevada       Elko and Lahonton
              Oregon       Brothers-LaPine and John Day
              Wvomina      Codv and Platte River




              Page 34               GAO/RCRD-90-225 Resource Management Planning
Appendix II

Major Contributors to This Report


                        James R. Hunt, Assistant Director
Resources,              Charles Barchok, Assignment Manager
Community, and          Diane Brooks, Staff Evaluator
Economic
Development Division,
Washington, D.C.
                        Richard Griffone, Evaluator-in-Charge
San Francisco           Judy Hoovler, Staff Evaluator
Regional Office




(140411)                Page 35                           GAo/RCED-90.225 Resource Management Planning
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